In the case of Roberts v. LaVallee, Warden (1967), the U.S Supreme Court ruled in favor of defendant David Roberts who was convicted for robbery in New York State courts. The court held that a confession obtained from him while he was detained without access to counsel violated his Sixth Amendment right to legal representation and Fourteenth Amendment right to due process under law. The decision reversed an earlier ruling by the Appellate Division of the Supreme Court of New York which had upheld Robert's conviction on grounds that he did not specifically request a lawyer during his detention period before making his confession. However, this argument was rejected by Justice William O Douglas who delivered the opinion for a unanimous court stating that it is not necessary for defendants to explicitly ask for their constitutional rights; they are entitled regardless.

In the dissenting opinion for Roberts v. Lavallee, it was argued that the majority's decision to grant a new trial based on lack of counsel during police interrogation undermined established legal principles. The dissenting justices believed that there was no constitutional right to counsel at every stage of criminal proceedings and emphasized that the defendant had been represented by competent attorneys throughout his trial and appeal processes. They also pointed out that he had not requested an attorney during his interrogation nor claimed any coercion or duress in giving statements to law enforcement officers. Therefore, they saw no reason why these statements should be deemed involuntary or unconstitutional simply because he did not have a lawyer present when making them.