In the case of Browder v. Director, Department of Corrections of Illinois (1977), the United States Supreme Court ruled that a federal court could not dismiss a habeas corpus petition on grounds that it was filed too late if there were no established time limits for such filings. The petitioner, Browder, had been convicted in an Illinois state court and sought to challenge his conviction through federal habeas corpus proceedings. However, the district court dismissed his petition because he did not file it within what they considered a "reasonable" time frame after exhausting all other legal remedies available to him in state courts. Upon appeal, the U.S Supreme Court reversed this decision stating that unless Congress establishes specific deadlines for filing habeas corpus petitions by statute law or procedural rules are set up by judicial bodies like Federal Rules Committee with Congressional approval; lower courts cannot arbitrarily impose their own deadlines.

In the dissenting opinion for Browder v. Director, Department of Corrections of Illinois, Justice William Rehnquist argued that the majority had misinterpreted both federal law and precedent in their decision to grant habeas corpus relief to a state prisoner who failed to appeal his conviction within the time frame set by state law. He contended that Congress intended for federal courts to defer more heavily to state court judgments when it passed amendments limiting habeas corpus petitions in 1966. Furthermore, he believed that previous Supreme Court decisions supported this interpretation and did not establish an absolute right for prisoners to have their constitutional claims heard by a federal court if they missed deadlines established by state laws. In essence, Justice Rehnquist disagreed with the majority's view on how much leeway should be given towards procedural defaults committed at the state level.