In the case of Lefkowitz, Attorney General of New York v. Newsome (1974), the U.S Supreme Court ruled in favor of Newsome, a man who had pleaded guilty to a crime without being informed that he could have access to free counsel if he couldn't afford one. The court held that under New York law, an individual's plea is not considered voluntary unless they are aware of their right to legal representation at no cost if they cannot afford it themselves. This ruling was based on the Sixth and Fourteenth Amendments which guarantee all individuals fair treatment within the criminal justice system regardless of their financial status. Therefore, because Newsome wasn’t made aware about his rights before pleading guilty, his conviction was overturned by the Supreme Court.

In the dissenting opinion for Lefkowitz v. Newsome, Justice Rehnquist argued that the majority's decision to allow a defendant who pleaded guilty to later challenge his conviction on constitutional grounds was inconsistent with previous court rulings and undermined the finality of plea agreements. He contended that when a defendant voluntarily pleads guilty, they should be seen as waiving their right to contest any non-jurisdictional defects in their case. This includes potential violations of constitutional rights prior to entering the plea agreement. Justice Rehnquist emphasized that allowing defendants who have admitted guilt to subsequently claim innocence undermines both public confidence in judicial proceedings and respect for law enforcement authorities' efforts in securing these pleas. Furthermore, he expressed concern about burdening courts with post-conviction hearings which could potentially lead into an endless cycle of litigation.