In the Turner v. Louisiana case of 1964, the U.S. Supreme Court unanimously ruled that a defendant was denied his right to an impartial jury as guaranteed by the Sixth Amendment due to close and continual contact with two key prosecution witnesses during trial recesses. The defendant, Billy Joe Turner, had been convicted for murder in Louisiana state court where two deputy sheriffs who were principal witnesses for the prosecution also served as jury custodians throughout his three-day trial. During this time they ate meals with jurors and engaged in conversations about various topics including aspects of the case itself which could have influenced their decision-making process. The Supreme Court held that even if these interactions did not result in actual prejudice against Turner, they still violated his constitutional rights because it created potential opportunities for bias or influence on behalf of law enforcement officers involved directly in prosecuting him.

In the dissenting opinion for Turner v. Louisiana, Justice Harlan argued that the majority's decision was based on an overly broad interpretation of due process rights and failed to consider practical implications. He contended that sequestration is a common practice in trials where intense public interest could potentially influence jurors' impartiality, and it would be impractical to expect complete isolation of jurors from officers who are tasked with their care during this period. Furthermore, he pointed out that there were no allegations or evidence suggesting any improper influences by these deputies on the jury’s verdict in this case. Therefore, he believed that overturning Turner's conviction solely because two key witnesses also happened to serve as bailiffs during jury sequestration set a dangerous precedent which could undermine future criminal proceedings.