In Rideau v. Louisiana, Wilbert Rideau was convicted of murder and sentenced to death by a state court in Calcasieu Parish, Louisiana. Prior to his trial, a local television station had broadcasted his confession three times to an audience that included nearly half the parish's population. The U.S Supreme Court overturned the conviction on grounds that Rideau had been denied due process under the Fourteenth Amendment because he did not receive a fair trial. The Court held that it was impossible for him to get an impartial jury after such widespread publicity of his confession and thus concluded that pretrial publicity can undermine the fairness of criminal proceedings if it pervades potential jurors' minds so much as they form opinions before hearing any evidence in court.

In the dissenting opinion for Rideau v. Louisiana, Justice Clark argued that the majority's decision was based on speculation rather than evidence. He contended that there was no proof to suggest that a fair trial could not be held in Calcasieu Parish despite the pre-trial publicity surrounding Rideau's case. According to him, it is possible for jurors to set aside their biases and judge a case solely based on its merits presented during trial proceedings. Furthermore, he pointed out inconsistencies in how courts handle cases with significant media coverage; some are moved while others are not without clear criteria guiding these decisions. Finally, he expressed concern about setting a precedent where any defendant who receives substantial press attention can demand a change of venue regardless of whether or not this publicity has actually prejudiced potential jurors against them.