In the case of Rose, Warden v. Clark (1985), the U.S. Supreme Court ruled that a jury instruction error in a state criminal trial did not automatically require habeas corpus relief under federal law unless it had substantial and injurious effect or influence on determining the jury's verdict. The respondent, Charles Clark was convicted for murder by Tennessee courts but appealed claiming an unconstitutional burden-shifting presumption in his jury instructions violated due process rights as per Sandstrom v Montana precedent. The Sixth Circuit Court agreed with him and granted habeas corpus relief without applying harmless-error analysis to determine if this mistake influenced the outcome of his trial significantly. However, upon reaching Supreme Court, it reversed this decision stating that such errors should be subjected to harmless-error review before granting any relief because they do not necessarily render entire proceedings fundamentally unfair or unreliable.

In the dissenting opinion for Rose, Warden v. Clark, Justice William Rehnquist argued that the majority's decision was inconsistent with previous Supreme Court rulings and undermined the authority of state courts. He contended that by ruling in favor of Clark on a federal habeas corpus petition, despite his failure to object at trial or appeal based on Sandstrom error (a legal term referring to an unconstitutional presumption), it violated procedural default rules which require defendants to raise all possible defenses during their initial trial or lose them forever. Furthermore, he disagreed with the majority's view that this type of error could be harmless beyond reasonable doubt because it removed from jury’s hands an essential element of proof - intent in murder cases – thus denying defendant fair trial rights guaranteed under Sixth Amendment.