The U.S. Supreme Court case Dretke v. Haley (2003) revolved around the issue of whether a federal habeas court can grant relief to a state prisoner who has demonstrated that his continued confinement violates the Constitution's prohibition on cruel and unusual punishment, even if he did not raise this claim in state court due to procedural default rules. Michael Wayne Haley was sentenced under Texas' habitual offender law for theft, but it later emerged that one of his prior convictions should not have been counted towards this status because it was minor. The Supreme Court ruled 8-1 in favor of Haley, stating that when an error results in a sentence exceeding statutory maximums, such an error is "not merely 'trial error'" but rather represents a fundamental miscarriage of justice excusing procedural default.

In the case of Dretke v. Haley, Justice Scalia's dissenting opinion argued that federal courts should not have jurisdiction to correct state court sentencing errors unless they result in a conviction for a crime that the defendant did not commit. He contended that it was inappropriate for federal courts to intervene in state criminal proceedings merely because an error might have been made during sentencing. According to him, such intervention undermines states' rights and disrupts their judicial processes without sufficient justification. Furthermore, he pointed out that there are other avenues available within the state system itself through which defendants can seek redress for any perceived injustices or mistakes at trial or during sentencing.