In the case of Morris v. Mathews (1985), the U.S. Supreme Court ruled that a defendant's constitutional rights were not violated when he was re-indicted and retried for aggravated murder after his original conviction for voluntary manslaughter had been overturned on appeal. The court held that this did not constitute double jeopardy, which is prohibited by the Fifth Amendment to the Constitution, because both charges arose from a single act and thus constituted one offense under Ohio law. Furthermore, it found no violation of due process in allowing evidence at trial about prior convictions or pending charges against him since they were relevant to establish motive and intent.

In the dissenting opinion for Morris v. Mathews, Justice William Rehnquist argued that the majority's decision to allow a defendant to introduce new evidence in a habeas corpus proceeding was inconsistent with previous rulings and undermined state court judgments. He contended that federal courts should not be used as forums for retrying cases already decided by state courts unless there is clear proof of constitutional violation. Furthermore, he criticized the majority's interpretation of Ohio law regarding lesser included offenses, arguing it went beyond their purview as Supreme Court Justices. In his view, this case did not meet standards set out in prior decisions for when new evidence could be introduced during habeas proceedings because there was no claim of actual innocence or denial of fair trial due to prosecutorial misconduct or ineffective counsel.