In the case of Miller v. Fenton, 1985, the U.S. Supreme Court ruled that a federal court must independently review whether or not a confession was voluntary in cases where this issue is disputed. The case involved Patsy Miller who had been convicted for murder based on his confession to police which he later claimed was coerced and therefore involuntary. His appeal reached the Supreme Court after lower courts upheld his conviction stating that they were bound by state court findings regarding voluntariness of confessions unless there's convincing evidence to suggest otherwise. However, the Supreme Court disagreed with this approach and held that federal habeas corpus law required independent determination of constitutional claims including voluntariness of confessions irrespective of any previous state court findings on these issues.

In the dissenting opinion for Miller v. Fenton, Justice White argued that the majority's decision to treat voluntariness of a confession as a legal issue requiring de novo review was inconsistent with previous Supreme Court rulings and federal habeas corpus law. He contended that this ruling would unnecessarily burden federal courts by forcing them to reevaluate state court findings without any clear benefit in terms of accuracy or fairness. Furthermore, he expressed concern about undermining the authority and expertise of state courts in determining factual issues related to confessions. In his view, whether a confession is voluntary should be treated primarily as an issue of fact based on specific circumstances rather than a question of law subject to independent federal review.