In the case of In re Schriver, 1894, the petitioner was a prisoner who sought habeas corpus relief from his conviction. He claimed that he had been denied effective assistance of counsel because his attorney had also represented a co-defendant with conflicting interests at trial. The Supreme Court held that in order to demonstrate ineffective assistance of counsel due to conflict of interest, it is not enough for a defendant merely to show that there was potential for conflict; rather, they must prove actual adverse effect on their lawyer's performance. Furthermore, the court ruled that even if such an impact were shown and thus Sixth Amendment rights violated, this would not automatically mean entitlement to habeas corpus relief unless it could be demonstrated there was reasonable probability outcome would have been different without such violation.

The dissenting opinion in the case of In re Schriver, Petitioner, 1894 argued that the majority's decision to deny habeas corpus relief was incorrect. The dissent believed that Schriver had been denied his constitutional right to effective assistance of counsel during his trial. They contended that a lawyer who has not met or spoken with their client before trial cannot provide adequate representation. Furthermore, they disagreed with the majority's view on harmless error analysis and asserted it should not be applied when a defendant is denied their Sixth Amendment right to counsel. The dissent also criticized the state court for failing to hold an evidentiary hearing on Schriver’s ineffective assistance claim and stated this failure deprived him of due process rights under Fourteenth Amendment.