In the case of Koehler, Warden v. Engle in 1983, the Supreme Court ruled on whether or not a group of Ohio prisoners could challenge their state convictions in federal court after failing to comply with an Ohio rule requiring them to raise all available claims on their first appeal. The prisoners argued that they had received ineffective assistance from their lawyers during trial and direct review stages. However, they did not make this claim until filing for post-conviction relief - which was beyond the time limit set by Ohio law. The Supreme Court held that these claims were procedurally defaulted and thus barred from federal habeas corpus review because they had not been raised at the appropriate time under state law. This decision reinforced respect for states' procedural rules while also emphasizing defendants' responsibility to assert all possible defenses promptly.

In the dissenting opinion for Koehler v. Engle, Justice White argued that the majority's decision was inconsistent with previous rulings and failed to properly apply federal habeas corpus law. He contended that the Court should have deferred to state court findings unless they were clearly erroneous or lacked fair support in the record. Instead, he believed, it had improperly reevaluated evidence and made its own determination of facts. Furthermore, he criticized the majority for not giving due weight to a defendant's strategic decisions during trial; if a defense counsel deliberately chose not to object at certain points as part of their strategy, then this could not be later claimed as ineffective assistance of counsel on appeal. Finally, Justice White disagreed with how retroactivity was applied in this case; he felt that new constitutional rules should only be applied retroactively if they increased accuracy in conviction or sentencing.