In the case of In Re Oliver (1948), the U.S. Supreme Court ruled that a Michigan law allowing for secret criminal trials was unconstitutional, violating both the Sixth and Fourteenth Amendments. The case involved an individual named Lloyd Warner Oliver who had been convicted in a one-man grand jury proceeding without being given notice or opportunity to defend himself. He was sentenced to jail for contempt of court but appealed his conviction on constitutional grounds. The Supreme Court agreed with him, stating that public trials are fundamental aspects of justice under American law and serve as safeguards against potential abuses by judicial authorities. This landmark decision established important precedents regarding due process rights and transparency in legal proceedings.

In the dissenting opinion for In Re Oliver, Justice Frankfurter disagreed with the majority's decision to overturn Oliver's conviction. He argued that due process does not necessarily require a public trial and that there are circumstances where a private trial may be necessary to protect the defendant or ensure justice is served. Furthermore, he contended that historical precedent did not support an absolute right to a public trial in all cases. The judge also expressed concern about federal courts intervening too much in state court proceedings, arguing it could undermine states' rights and disrupt their judicial systems. Finally, he suggested that if any changes were needed regarding secret trials they should come from legislation rather than judicial interpretation of constitutional law.