In the 1987 case of McCoy v. Court of Appeals of Wisconsin, District 1, the U.S Supreme Court ruled that federal courts cannot review state court decisions on post-conviction relief if they are based on adequate and independent state grounds. The petitioner, McCoy, had been convicted in a Wisconsin court for armed robbery and first-degree murder. He sought to have his conviction overturned due to ineffective assistance from his counsel during trial but was denied by both the Wisconsin Court of Appeals and State Supreme Court. When he appealed this decision to a Federal District Court via habeas corpus petition it was dismissed as well because it found that there were no constitutional issues at stake since the claim rested solely upon an interpretation or application of state law rather than federal law.

In the dissenting opinion for McCoy v. Court of Appeals of Wisconsin, District 1, Justice Brennan disagreed with the majority's view that a defendant has no constitutional right to self-representation on direct appeal from a criminal conviction. He argued that such a right is inherent in the Sixth Amendment and Fourteenth Amendment due process clause. According to him, these amendments guarantee an individual’s autonomy to personally control his own defense during trial proceedings and this should extend to appeals as well. Furthermore, he contended that denying defendants their right to self-representation could potentially undermine public confidence in our judicial system by creating an impression of unfairness or bias against those who cannot afford legal representation or choose not represent themselves for other reasons.