In the 1941 case Pierce v. United States, the Supreme Court ruled on whether a defendant could withdraw their guilty plea after sentencing but before imprisonment. The defendants were charged with conspiracy to defraud the U.S., and initially pleaded not guilty, but later changed their pleas to guilty. After being sentenced, they sought to change their pleas back to not guilty claiming that they had been coerced into pleading guilty by government agents who promised them leniency if they did so. The trial court denied this motion and an appeal was made to the Supreme Court. The Supreme Court held that once a sentence has been imposed following a valid plea of guilt, it cannot be withdrawn unless there is some fundamental defect in proceedings or some procedure required by law was not followed correctly during sentencing process which would render judgement void or illegal. In this case, no such defects were found; therefore defendants' request for withdrawal of their pleas was denied.

In the dissenting opinion for Pierce v. United States, Justice Hugo Black argued that the majority's decision to uphold a conviction based on an indictment that was not specific enough violated the defendants' Sixth Amendment rights. He believed that by allowing such vague indictments, it would be impossible for defendants to prepare their defense adequately or protect against future prosecutions for the same offense. Furthermore, he contended that this ruling undermined a fundamental principle of American justice - namely, providing individuals with notice of accusations against them so they can defend themselves effectively in court. In his view, any indictment should clearly state what crime has been committed and how it violates federal law; otherwise, it is constitutionally deficient and cannot form a valid basis for prosecution.