In the case of Von Moltke v. Gillies, 1947, the U.S Supreme Court ruled in favor of Mrs. Elfriede Ottillie von Moltke who had been convicted for conspiracy to violate the Espionage Act during World War II. The court held that her constitutional rights were violated as she did not have effective counsel at her trial and was not adequately informed about her right to legal representation or the implications of waiving such a right before pleading guilty. The decision emphasized that defendants should be provided with "real notice" regarding their rights and potential consequences when making decisions related to their defense strategy, including entering a plea deal without proper understanding or advice from competent counsel.

In the dissenting opinion for Von Moltke v. Gillies, Justice Jackson disagreed with the majority's decision to overturn Ms. Von Moltke's conviction on grounds that she was not adequately informed of her rights before pleading guilty. He argued that there was no evidence suggesting that she did not understand what a plea of guilty meant or its consequences, and thus saw no reason why her plea should be invalidated simply because it wasn't made in open court or recorded verbatim. Furthermore, he contended that the Court had overstepped its bounds by imposing new procedural requirements on state courts without any constitutional basis for doing so.