In the case of Anderson, Warden v. Harless in 1982, the U.S Supreme Court ruled that a Michigan state prisoner's federal habeas corpus petition was procedurally defaulted because he failed to fairly present his claim to the state courts as a federal constitutional issue. The petitioner had argued that his confession was coerced and thus violated due process but did not explicitly cite "due process" or reference any specific provision of the Constitution when presenting this argument in state court. The Supreme Court held that it is not enough for a petitioner merely to discuss facts constituting an alleged violation; they must also clearly indicate which specific rights guaranteed by the Constitution are being implicated.

In the dissenting opinion for Anderson, Warden v. Harless, Justice Stevens argued that the majority's decision was based on a misinterpretation of Michigan law and an incorrect application of federal habeas corpus principles. He contended that the defendant had adequately presented his claim in state court as required by Picard v. Connor (1971), which states that a prisoner must fairly present their claims to state courts before seeking federal habeas relief. The majority held that because Harless did not cite "specifically" to a constitutional provision or use "particular legal phrases," he failed this requirement - an interpretation Justice Stevens disagreed with vehemently, arguing it imposed too high a standard on defendants who may lack legal expertise and resources.