In the case of Payne v. Madigan, Warden (1960), the United States Supreme Court ruled that a state prisoner who had been denied access to federal court by way of habeas corpus could not be barred from seeking relief in federal court under Section 2255 of Title 28. The petitioner, Payne, was convicted for murder and sentenced to death in Illinois State Courts. He sought post-conviction relief through habeas corpus but was denied by both the District Court and Seventh Circuit Court due to procedural default rules which stated he had failed to exhaust all his state remedies before approaching Federal courts. However, upon reaching the Supreme Court it held that since Section 2255 is an independent civil suit separate from original criminal proceedings, different standards apply including those related to procedural defaults at state level hence allowing him another chance at Federal review.

The dissenting opinion in the case of Payne v. Madigan, Warden argued that the petitioner's constitutional rights were violated due to a lack of counsel during his trial. The dissenting justices believed that because Payne was not provided with an attorney during his arraignment and plea, he did not fully understand the charges against him or the potential consequences of pleading guilty. They contended that this situation constituted a violation of due process under both state law and federal constitution. Furthermore, they disagreed with majority’s view on harmless error doctrine application in this case as they considered it inappropriate given these circumstances where fundamental fairness is at stake.