In the 1951 case of Gallegos v. Nebraska, the U.S Supreme Court ruled in favor of a Mexican national who was convicted for murder in Nebraska. The defendant, Jesus Gallegos, argued that his confession had been obtained through coercion and thus violated his constitutional rights under the Fourteenth Amendment's due process clause. He claimed that he was held incommunicado by police for five days without being informed of his right to counsel or contact with consular officials from Mexico as required by international treaty obligations (the "Havana Convention"). In its decision, the court did not directly address these issues but instead focused on whether there were sufficient grounds to believe that Gallegos' confession had been coerced. Ultimately, it found evidence suggesting this possibility and therefore ordered a new trial where such factors could be properly considered.

In the dissenting opinion for Gallegos v. Nebraska, Justice Frankfurter argued that the majority's decision was a departure from established legal principles and an intrusion into state jurisdiction. He contended that it is not within the Supreme Court's purview to assess whether or not a confession was voluntary based on its own standards; rather, this should be left to state courts which are more familiar with local conditions and practices. Furthermore, he disagreed with the majority’s assertion that Gallegos’ youthfulness made his confession involuntary by default as there were no clear signs of coercion or intimidation in obtaining his statement. The justice also pointed out inconsistencies in applying federal law over state law when dealing with confessions obtained from minors versus adults - arguing for uniformity across all cases regardless of age difference.