In the 1960 Supreme Court case Reynolds v. Cochran, Director of Division of Corrections, petitioner Reynolds was convicted in a Florida state court for breaking and entering with intent to commit grand larceny. He sought habeas corpus relief from his conviction on the grounds that he had been denied due process because he was not provided counsel during his trial. The District Court dismissed this petition without hearing evidence or making findings of fact regarding whether Reynolds had waived his right to counsel knowingly and intelligently as required by law. On appeal, the U.S Supreme Court held that it is necessary for courts to make explicit findings about whether an accused has competently and intelligently waived their constitutional right to assistance of counsel before they can be tried without one. Therefore, the judgment was reversed and remanded back to district court for further proceedings consistent with this opinion.

The dissenting opinion in the case of Reynolds v. Cochran, Director of Division of Corrections, 1960 was not provided or recorded in the available legal documents and resources. Therefore, a summary cannot be produced for it.