In the case of Westbrook v. Arizona in 1965, the United States Supreme Court was tasked with determining whether a state could constitutionally require an individual to pay for their own court-appointed counsel if they were able to do so. The appellant, Westbrook, had been convicted of first-degree murder and sentenced to death by an Arizona court. He appealed this decision on several grounds including that he was forced to pay for his own defense despite being indigent at the time of trial. However, upon review, it was determined that Westbrook did have sufficient funds available from selling his property while awaiting trial and thus could afford legal representation without undue hardship. Therefore, requiring him to bear these costs did not violate his constitutional rights under the Sixth Amendment which guarantees all defendants access to counsel regardless of ability to pay.

The dissenting opinion in the case of Westbrook v. Arizona argued that the petitioner's Sixth Amendment rights were violated when he was denied counsel during his preliminary hearing, a critical stage in criminal proceedings. The dissenters believed that this denial had significant implications on the outcome of Westbrook's trial and subsequent conviction for armed robbery. They contended that without legal representation at this early stage, an accused person may be disadvantaged later in their defense strategy as they would not have been able to cross-examine witnesses or challenge evidence presented against them effectively. This could potentially lead to wrongful convictions due to lack of proper legal guidance and protection from self-incrimination during initial stages of prosecution process.