In the case of McNeal v. Culver, State Prison Custodian (1960), petitioner William McNeal was convicted for armed robbery in a Georgia state court and sentenced to life imprisonment. He appealed his conviction on the grounds that he had been denied due process because he was not allowed to cross-examine one of the prosecution's key witnesses - an accomplice who testified against him but later recanted his testimony. The Supreme Court ruled in favor of McNeal, holding that a defendant has a constitutional right under the Sixth Amendment to confront and cross-examine witnesses against them as part of their right to a fair trial. This decision reaffirmed that this fundamental aspect of due process applies at both federal and state levels.

In the dissenting opinion for McNeal v. Culver, Justice Frankfurter argued that the majority's decision to grant habeas corpus relief was incorrect because it overlooked important procedural aspects of the case. He contended that McNeal had not exhausted all available state remedies before seeking federal intervention, which is a prerequisite for granting such relief under federal law. Furthermore, he believed that there were significant questions about whether or not McNeal’s constitutional rights had been violated in his original trial and sentencing - issues which should have been addressed by state courts first. Therefore, according to Justice Frankfurter's dissenting view, this case represented an inappropriate overreach of federal authority into matters properly handled at the state level.