In the 1962 case of White v. Maryland, the U.S. Supreme Court ruled in favor of petitioner Albert White Jr., who had been convicted for murder by a Maryland court without being represented by an attorney during his preliminary hearing. The issue at hand was whether a plea made at this initial stage could be used against him later on in trial when he did have legal representation. The Supreme Court held that it was unconstitutional to use such pleas as evidence if the defendant didn't have access to counsel when they were entered, basing their decision on due process rights under the Fourteenth Amendment and right to counsel under Sixth Amendment. This ruling expanded upon previous decisions regarding defendants' rights and further emphasized that these protections apply from the moment criminal proceedings begin.

In the dissenting opinion for White v. Maryland, it was argued that the defendant's plea at a preliminary hearing should not be considered as evidence in his trial because he did not have legal representation present during this initial proceeding. The dissenting justices believed that using such a plea as evidence violated the defendant's constitutional rights to due process and fair trial under the Fifth and Sixth Amendments. They contended that any statement made by an accused person outside of their own defense in court is inherently unreliable and prejudicial, especially when made without counsel’s advice or presence. Therefore, they disagreed with the majority ruling which upheld White's conviction based on his uncounseled guilty plea from a preliminary hearing being used against him at trial.