In the case of Geders v. United States, the Supreme Court ruled in 1976 that a trial court order directing a defendant not to consult with his lawyer during a 17-hour overnight recess violated his Sixth Amendment right to counsel. The defendant, John H. Geders, was on trial for distributing obscene materials through interstate commerce and had been ordered by the district judge not to discuss any aspect of his testimony with anyone including his attorney during an overnight break in proceedings. This directive was given after Mr.Geders completed direct examination but before cross-examination began.The Supreme Court held that such an order deprived him of "the guiding hand of counsel" at a critical stage in the proceedings and thus constituted reversible error.

In the dissenting opinion for Geders v. United States, Justice White argued that the majority's decision to reverse Geders' conviction due to a trial judge's order preventing him from consulting with his lawyer during an overnight recess was incorrect. He contended that this restriction did not violate the defendant’s Sixth Amendment right to counsel as it only applied during a brief period and did not prevent communication about other matters unrelated to testimony. Furthermore, he pointed out that such restrictions are common in trials and do not necessarily infrive on defendants’ rights; they can actually serve important purposes like preventing coaching or collusion between lawyers and witnesses. Therefore, according to Justice White, there should be no automatic reversal of convictions when such orders are issued by judges unless there is clear evidence showing specific prejudice against the defendant resulting from this action.