Some states had direct appeals of criminal convictions earlier than this but the writ of
habeas corpus does precede a direct appeal as a form of relief from a wrongful criminal conviction historically and was the primary means by which one could obtain relief from a criminal conviction in 1789 when the U.S. Constitution, which
preserved the right to seek a writ of
habeas corpus even before the Bill of Rights added most other new criminal procedure rights under the constitution, was adopted.