In Smith v. Crouse, the U.S Supreme Court ruled in favor of a habeas corpus petitioner who had been convicted without being provided counsel. The defendant, Mr. Smith, was charged with burglary and larceny but could not afford an attorney for his defense at trial or on appeal to the Kansas Supreme Court where he was sentenced to 10-21 years imprisonment. He filed a petition for writ of habeas corpus arguing that his constitutional rights were violated as he did not have legal representation during these proceedings which is guaranteed by the Sixth Amendment right to counsel clause under Gideon v Wainwright ruling (1963). The District Court dismissed this petition stating it lacked merit because Gideon's case only applied prospectively and not retroactively i.e., it didn't apply to cases prior its decision date. However, upon review by the U.S Supreme court they reversed this decision holding that "Gideon v Wainwright is made fully retroactive" meaning all individuals tried without counsel are entitled relief regardless of when their conviction occurred.

In the dissenting opinion for Smith v. Crouse, it was argued that the petitioner's constitutional rights were not violated when he pleaded guilty to a crime without legal representation. The justice believed that since the defendant had voluntarily confessed his guilt and there was no evidence of coercion or unfair treatment, his conviction should stand. Furthermore, they pointed out that at no point did Smith request an attorney nor claim ignorance about his right to one during trial proceedings. They also noted that providing counsel to every individual who pleads guilty could potentially overwhelm the judicial system with unnecessary costs and delays in court proceedings. Therefore, they disagreed with majority’s decision which held this as a violation of Sixth Amendment rights.