In Turner v. Pennsylvania, the U.S Supreme Court ruled that a defendant's constitutional rights were violated when he was denied counsel during his preliminary hearing and trial. The case involved an African-American man named Edward Turner who was convicted of first-degree murder in Pennsylvania without legal representation. He appealed to the Supreme Court arguing that this denial of counsel infringed upon his Sixth Amendment right to have Assistance of Counsel for his defense, as well as Fourteenth Amendment due process protections. The court agreed with Turner and reversed his conviction on these grounds, establishing a precedent for ensuring defendants' access to legal representation throughout all stages of criminal proceedings.

In the dissenting opinion for Turner v. Pennsylvania, Justice Frankfurter argued that the majority's decision to overturn Turner's conviction was based on an incorrect interpretation of due process rights under the Fourteenth Amendment. He contended that while it is indeed a violation of due process for a jury to be influenced by outside sources, there was insufficient evidence in this case to suggest such influence had occurred. The mere fact that jurors read newspaper articles about the trial did not necessarily mean they were biased or prejudiced against Turner; rather, it would only become problematic if these readings led them to form an opinion before hearing all evidence and arguments in court. Furthermore, he pointed out inconsistencies in how different states handle potential juror bias from media exposure and suggested more uniform standards are needed across jurisdictions.