In the 1974 case Murphy v. Florida, the United States Supreme Court ruled that a defendant's right to an impartial jury was not violated by pretrial publicity unless there was a "wave of public passion" that created a presumption of prejudice against him. The court held that media coverage alone does not automatically mean jurors are biased and unable to deliver fair judgment. In this particular case, Jack Roland Murphy had argued his robbery conviction should be overturned because he could not get a fair trial due to extensive media coverage about his previous convictions for unrelated crimes. However, the Supreme Court disagreed with Murphy’s argument stating that most of the news articles were more than one year old and did not refer directly to the crime in question.

In the dissenting opinion for Murphy v. Florida, Justice Marshall argued that the majority's decision failed to adequately protect a defendant's Sixth Amendment right to an impartial jury. He contended that pretrial publicity had so pervaded the community that it was impossible for Murphy to receive a fair trial in Palm Beach County. The justice believed there should have been more rigorous standards applied by courts when determining whether or not potential jurors were biased due to media exposure of high-profile cases like this one. Furthermore, he criticized the majority’s reliance on juror self-assessment of their own impartiality as being inherently unreliable and insufficient in ensuring fairness during trials with significant public attention.