In the case of Ashe, Warden of the State Penitentiary v. United States ex rel. Valotta (1925), the U.S Supreme Court ruled in favor of Valotta, an inmate who was seeking habeas corpus relief from his imprisonment for a crime he claimed he did not commit. The court found that there had been a violation of due process because evidence crucial to Valotta's defense was excluded during his trial and this exclusion significantly impacted its outcome. Furthermore, it was determined that the state courts had failed to provide him with an opportunity for redress or appeal regarding this issue. Therefore, based on these findings, the Supreme Court ordered that Valotta be released from custody unless within a reasonable time period set by lower federal courts; he is retried under conditions respecting constitutional safeguards.

In the dissenting opinion for Ashe v. United States ex rel. Valotta, Justice McReynolds argued that the majority's decision to grant habeas corpus relief was incorrect and not supported by existing legal precedent or principles of justice. He contended that Valotta had been lawfully convicted in state court and should serve his sentence as determined by those proceedings, rather than being released on a technicality related to extradition procedures between states. Furthermore, he expressed concern about potential negative implications of this ruling for future cases involving interstate criminal matters, suggesting it could undermine respect for state courts' judgments and disrupt cooperative law enforcement efforts among states.