In the case of New York ex rel. Whitman v. Wilson, Warden in 1942, the U.S Supreme Court ruled that a state court's decision could not be reviewed by a federal court if it was based on an adequate and independent state ground. The petitioner, Whitman, had been convicted for first-degree murder in New York and sentenced to death. He appealed his conviction to the U.S Supreme Court arguing that he was denied due process because certain evidence used against him at trial should have been excluded as it violated his Fourth Amendment rights against unreasonable searches and seizures. However, both the State Appellate Division and Court of Appeals affirmed his conviction stating that even without considering this disputed evidence there were other sufficient grounds for upholding his sentence based on overwhelming additional proof presented during trial which established guilt beyond reasonable doubt. The U.S Supreme Court dismissed Whitman’s appeal agreeing with lower courts' decisions emphasizing its inability to review judgments resting upon an adequate non-federal ground.

In the dissenting opinion for New York ex rel. Whitman v. Wilson, Justice Frank Murphy argued that the majority's decision was a departure from established principles of federalism and judicial restraint. He contended that it was not within the jurisdiction of federal courts to interfere with state court decisions unless there were clear violations of constitutional rights, which he did not believe existed in this case. Furthermore, he expressed concern about potential overreach by federal courts into matters traditionally handled by states if they could intervene based on mere disagreement with how state courts interpret their own laws or constitution. In his view, such intervention should be limited to cases where state action clearly infringes upon federally protected rights.