The U.S. Supreme Court case Black, Director, Missouri Department of Corrections and Human Resources, et al. v. Romano in 1984 centered around the issue of whether a state prisoner who had been denied parole could challenge that denial through a federal habeas corpus petition on the grounds that it violated his due process rights under the Fourteenth Amendment to the Constitution. The petitioner argued that he was entitled to be released on parole unless there were legitimate reasons for denying him this privilege based on his behavior while incarcerated or other relevant factors. However, the Supreme Court ruled against him by stating that there is no constitutional or inherent right of a convicted person to be conditionally released before serving their full sentence. It further clarified that states have broad discretion in determining how they will administer their parole systems and are not required by federal law to provide specific procedural protections during these proceedings beyond what is already provided for under state law. Therefore, according to this ruling, prisoners cannot use federal habeas corpus petitions as means to challenge denials of parole if they believe such decisions violate their due process rights.

In the dissenting opinion for Black, Director, Missouri Department of Corrections and Human Resources v. Romano (1984), Justice Stevens argued that the majority's decision was inconsistent with previous rulings regarding a defendant's right to self-representation. He contended that while it is important to ensure fair trials by providing competent counsel, this should not override an individual’s constitutional right to represent themselves if they so choose. According to him, the court had previously upheld this principle even in cases where defendants were deemed mentally incompetent or their defense strategy was questionable. Therefore, he believed that denying Romano his request for self-representation based on concerns about his ability or strategy contradicted these precedents and infringed upon his Sixth Amendment rights.