In the case of Gonzales v. United States in 1959, the U.S Supreme Court ruled that a defendant has the right to have their sanity evaluated by a jury before being convicted. The petitioner, Richard Gonzales was charged with transporting stolen goods across state lines and pleaded not guilty on grounds of insanity at time of offense. However, his request for an independent psychiatric examination was denied by lower courts which led him to appeal to the Supreme Court. The court held that it is unconstitutional under Section 4244 of Title 18 (which provides for mental examination and hearing after arrest and before trial) to deny such requests without providing reasonable opportunity for defendants to gather evidence regarding their mental condition during alleged crime commission period.

In the dissenting opinion for Gonzales v. United States, Justice Frankfurter argued that the majority's decision to allow defendants in federal criminal trials to waive their right to a jury trial was not supported by historical precedent or constitutional interpretation. He contended that the Sixth Amendment clearly established an individual's right to a jury trial and did not provide any provision for waiving this right. Furthermore, he pointed out that throughout history, courts have consistently upheld this fundamental principle of American jurisprudence. In his view, allowing defendants to waive their rights would undermine public confidence in the judicial system and could potentially lead to abuses of power by prosecutors and judges. Therefore, he believed it was essential for all federal criminal trials involving serious offenses be decided by juries rather than single judges.