In the case of Murphy v. Massachusetts, 1899, the U.S Supreme Court upheld a decision by the Massachusetts Supreme Judicial Court which convicted and sentenced John J. Murphy to death for first-degree murder. The defendant appealed on grounds that his constitutional rights were violated as he was not present during a critical stage of his trial - when the judge instructed jurors in response to their questions about evidence while deliberating on verdicts. However, Justice Rufus Wheeler Peckham delivered an opinion stating that no federal question was involved since it did not appear from record whether or not state law required defendant's presence at such time; hence there was no violation under Fourteenth Amendment due process clause.

In the dissenting opinion for Murphy v. Massachusetts, Justice Harlan argued that the defendant's constitutional rights were violated due to a lack of fair trial. He contended that the jury was influenced by public sentiment against him and his alleged crime, which led to an unjust verdict. The justice emphasized that every citizen has a right to be tried in an impartial court regardless of their offense or personal character. Furthermore, he believed it was inappropriate for jurors who had expressed prejudice against the accused prior to trial proceedings to serve on his case as this could compromise their objectivity and fairness in decision-making. Therefore, Justice Harlan disagreed with the majority ruling upholding Murphy's conviction because he felt it did not uphold principles of equal protection under law guaranteed by Fourteenth Amendment.