In the case of Brown v. Allen, Warden (1952), the U.S Supreme Court addressed two main issues: racial discrimination in jury selection and ineffective assistance of counsel. The petitioners were African-American men convicted for rape by all-white juries in North Carolina. They claimed their constitutional rights were violated due to systematic exclusion of black people from juries and inadequate legal representation during their trials. The court held that while there was no evidence proving intentional racial discrimination in jury selection, it acknowledged potential bias but ruled it insufficient to overturn the convictions. Regarding ineffective counsel claim, they found no violation as well since defendants had lawyers who actively participated throughout proceedings even though they might have made errors or omissions which did not necessarily equate to a denial of fair trial under 14th Amendment's Due Process Clause.

In the dissenting opinion for Brown v. Allen, Justice Jackson disagreed with the majority's decision to grant habeas corpus relief in state criminal cases where federal constitutional issues have been decided against a petitioner by a state court. He argued that this would undermine the authority of state courts and create an unnecessary burden on federal courts. Furthermore, he contended that it was not within the jurisdiction of federal courts to reevaluate factual determinations made by state courts based on evidence presented at trial. Instead, they should only intervene when there is clear proof of a violation of constitutional rights or gross injustice. In his view, granting such broad powers to review decisions made by competent and fair-minded judges in lower courts could lead to misuse and abuse.