In the case of Holley v. Lawrence, Warden (1942), the United States Supreme Court reviewed a decision by lower courts to deny habeas corpus relief to an inmate who was convicted for murder and sentenced to death in Virginia. The petitioner, Holley, argued that his constitutional rights were violated because he did not have access to counsel during his preliminary hearing and when he entered a plea before a magistrate. However, the Supreme Court upheld the decisions of lower courts denying habeas corpus relief on grounds that no federal question had been presented as there was no denial or infringement of any specific federal right under Fourteenth Amendment due process clause. The court noted that while it is desirable for defendants in capital cases to have legal representation at all stages of proceedings, failure to provide such does not necessarily constitute violation of due process unless prejudice can be shown resulting from lack thereof.

In the dissenting opinion for Holley v. Lawrence, it was argued that the petitioner's constitutional rights were violated due to his lack of counsel during a critical stage in his trial process. The dissenting justices believed that this denial of legal representation infringed upon Holley's Sixth Amendment right to have assistance of counsel for his defense. They contended that the absence of an attorney during such a crucial part in proceedings could significantly impact and prejudice the outcome against him, thus denying him fair trial as guaranteed by law. Therefore, they disagreed with the majority ruling which upheld Holley’s conviction despite these concerns about procedural fairness and constitutionality.