In Sublett v. Adams, Warden (1959), the petitioner, Sublett, was convicted of murder in a California state court and sentenced to death. He appealed his conviction on the grounds that he had been denied due process because of an alleged violation of the Fourteenth Amendment's Equal Protection Clause. Specifically, he claimed that African Americans were systematically excluded from both grand and petit juries in Alameda County where his trial took place. The Supreme Court dismissed this claim as it found no evidence supporting systematic exclusion based on race from jury service in Alameda County at the time of Sublett’s trial or indictment by grand jury.

In the dissenting opinion for Sublett v. Adams, it was argued that the petitioner's constitutional rights were violated due to a lack of counsel during his trial. The dissenting justices believed that this case should have been reviewed by the Supreme Court because it raised serious questions about whether or not an individual can receive a fair trial without legal representation. They pointed out that while some individuals may be able to adequately represent themselves in court, many others cannot and therefore are at a significant disadvantage if they do not have access to counsel. This is particularly true in complex cases where understanding of legal procedures and precedents is crucial. Therefore, they disagreed with the majority decision denying review of this case as they felt it undermined principles of justice and fairness underpinning American law system.