In the 1984 case of Patrick Ramirez v. Indiana, the U.S Supreme Court was asked to consider whether a defendant's Sixth Amendment right to confront witnesses against him had been violated. The issue arose from an incident where Ramirez was convicted for burglary and confinement based on testimony given by his alleged accomplice in a separate trial that did not involve Ramirez directly. This testimony was used against him despite the fact that he could not cross-examine this witness during his own trial because she invoked her Fifth Amendment privilege against self-incrimination when called upon to testify at his trial. The court ruled in favor of Indiana, stating that there were sufficient "indicia of reliability" surrounding the accomplice's statements which made them trustworthy enough for use as evidence even without cross-examination by Ramirez himself.

The dissenting opinion in the case of Patrick Ramirez v. Indiana argued that the majority's decision to uphold Ramirez's conviction was a misinterpretation of the law and an infringement on his constitutional rights. The dissenting justices believed that there were significant procedural errors during Ramirez's trial, including improper jury instructions and evidence handling, which violated his right to due process under the Fourteenth Amendment. They also disagreed with how Indiana’s felony murder rule was applied in this case, arguing it should not be used when a co-perpetrator is killed by a victim or police officer during commission of crime; instead they suggested it should only apply if defendant or accomplice caused death while committing underlying felony. Furthermore, they contended that upholding such convictions could potentially lead to unjust outcomes where defendants are held accountable for unforeseeable actions taken by others outside their control or intent.