In the 1955 case United States ex rel. Darcy v. Handy, Warden, et al., the Supreme Court addressed a habeas corpus petition from an individual convicted of murder in Pennsylvania state court and sentenced to death. The petitioner argued that his constitutional rights were violated because he was not given access to counsel during his preliminary hearing and when making a confession to police officers. He also claimed that evidence used against him at trial was obtained through illegal search and seizure procedures by law enforcement officials. The Supreme Court ruled in favor of the respondent, stating that there had been no violation of federal constitutional rights as alleged by Darcy since it wasn't required for defendants to have legal representation at preliminary hearings under Pennsylvania law at the time nor did they find any coercion or duress involved in obtaining Darcy's confession which could render it involuntary or unconstitutional. Furthermore, they found no proof supporting claims about illegally seized evidence being used against him. This decision reinforced states' autonomy over their own criminal proceedings unless clear violations of federally protected rights are proven.

In the dissenting opinion for UNITED STATES ex rel. DARCY v. HANDY, WARDEN, et al., Justice Frankfurter argued that the Court had overstepped its bounds by intervening in a state court matter and disregarding Pennsylvania's procedural rules. He contended that Darcy had not exhausted all available remedies at the state level before seeking federal habeas corpus relief, as required by law. Furthermore, he believed there was no constitutional violation to justify such intervention since Darcy received a fair trial with competent counsel who made strategic decisions about what evidence to present or withhold based on their professional judgment. Thus, according to Justice Frankfurter’s dissenting view, it was inappropriate for the Supreme Court to second-guess these tactical choices under guise of due process review.