In Rice v. Olson, the U.S Supreme Court ruled in 1944 that a defendant's right to counsel was violated when his attorney failed to adequately represent him during trial. The case involved an indigenous man named Fred Rice who had been convicted of first-degree murder by a South Dakota court and sentenced to death. He appealed on the grounds that he did not understand English well enough to comprehend what was happening at his trial, and thus could not effectively participate in his own defense or communicate with his lawyer. His appeal also claimed that he received inadequate representation from his appointed counsel who didn't properly investigate or present evidence regarding potential defenses such as self-defense or insanity due to alcoholism. The Supreme Court agreed with Rice’s arguments, stating that while there is no absolute right for defendants facing capital punishment cases to have their preferred choice of legal representation, they are entitled under the Sixth Amendment of Constitution for effective assistance of counsel which includes proper investigation into all plausible lines of defense.

In the dissenting opinion for Rice v. Olson, Justice Robert H. Jackson argued that the majority's decision to grant habeas corpus relief was based on a misinterpretation of South Dakota law and an overreach of federal authority into state matters. He contended that there was no evidence to suggest that Rice had been denied due process or equal protection under the law, as required by the Fourteenth Amendment for federal intervention in a state criminal case. Furthermore, he asserted that it is not within the jurisdiction of federal courts to interpret or correct errors in state court decisions unless they involve constitutional violations. In his view, this case did not meet those criteria because Rice received adequate legal representation during his trial and appeal processes in South Dakota courts.