In Waley v. Johnston, the petitioner, George Waley was convicted of kidnapping and sentenced to 45 years in prison. He appealed his conviction on the grounds that he had been denied effective counsel during his trial because his attorney did not challenge the admissibility of certain evidence or cross-examine key witnesses. The Supreme Court ruled in favor of Waley, stating that a defendant's right to competent legal representation is fundamental and essential for a fair trial under the Sixth Amendment. This case established an important precedent regarding ineffective assistance of counsel claims; it held that if a defendant can demonstrate their lawyer’s performance fell below an objective standard of reasonableness and this deficient performance prejudiced their defense, then they are entitled to relief.

The dissenting opinion in the Waley v. Johnston case argued that the court should have granted a hearing to consider whether or not Waley's plea was coerced, as he claimed it was. The dissenting justices believed that if his allegations were true, then his constitutional rights had been violated and justice would not be served by denying him an opportunity to present evidence supporting these claims. They felt that due process required a fair chance for every defendant to defend themselves against charges brought against them, regardless of how they initially entered their plea. This view held that even if a guilty plea is voluntarily made at first but later alleged to have been coerced, such claim must still be investigated thoroughly in order to uphold principles of fairness and justice inherent in the American legal system.