In the case of Coleman Wayne Gray v. J.D. Netherland, Warden in 1995, the United States Supreme Court ruled against Gray's appeal for habeas corpus relief from his death sentence. The court held that procedural default rules applied to claims not raised during state-level proceedings and could bar federal review unless cause and prejudice were shown or a miscarriage of justice would result if not considered. Gray was convicted for capital murder, robbery, and firearms possession in Virginia state court but failed to raise certain issues at trial or on direct appeal which he later sought to argue before federal courts. The Supreme Court found no cause for bypassing procedural default as there was no evidence that an objective factor external to the defense prevented counsel from raising these claims earlier nor any fundamental miscarriage of justice resulting from failure to consider them.

In the dissenting opinion for Coleman Wayne Gray v. J.D. Netherland, Justice Stevens argued that the majority's decision was inconsistent with previous rulings regarding habeas corpus petitions and ineffective assistance of counsel claims. He contended that Gray had been denied his constitutional right to effective legal representation during sentencing because his lawyer failed to present mitigating evidence about his background and mental health issues, which could have potentially spared him from a death sentence. Furthermore, he criticized the majority's application of procedural default rules in this case as overly rigid and unfair towards defendants who are not adequately represented by their lawyers at trial or on appeal. In essence, Justice Stevens believed that the Court should have granted Gray relief due to these serious errors made by his defense attorney.