In the case of Engle, Correctional Superintendent v. Isaac in 1981, the United States Supreme Court addressed whether or not a prisoner could challenge his conviction on constitutional grounds after having failed to do so during trial and appeal. The court ruled that if a defendant had an opportunity to raise such issues at trial but did not, then they cannot later use federal habeas corpus proceedings as another chance for review. This decision was based on principles of finality and respect for state courts' ability to correct their own mistakes. The majority opinion held that while it is important for prisoners to have access to federal courts through habeas corpus petitions, this should be balanced against potential abuse of the system by those who fail to follow proper procedures at earlier stages in their cases.

In the dissenting opinion for Engle, Correctional Superintendent v. Isaac, Justice William Rehnquist argued that the majority's decision to allow federal courts to review state court convictions on grounds of ineffective counsel was an overreach and a violation of principles of federalism. He contended that such issues should be left to state courts unless there is clear evidence that they are unable or unwilling to protect defendants' constitutional rights. Furthermore, he expressed concern about the potential for this ruling to open up floodgates of litigation from prisoners claiming their attorneys were inadequate. He also disagreed with the majority's interpretation of precedents related to habeas corpus petitions and believed it expanded them beyond their intended scope.