In the case of Estelle, Corrections Director v. Dorrough in 1974, the U.S Supreme Court ruled on a matter concerning constitutional rights within prison systems. The respondent, Dorrough, was an inmate who had been denied parole and claimed that his constitutional rights were violated because he was not given access to certain documents used by the Texas Department of Corrections during his parole hearing. He argued this denial infringed upon his due process rights under the Fourteenth Amendment. However, the Supreme Court disagreed with Dorrough's claim and held that there is no federal right for inmates to view or challenge information presented at their parole hearings as long as basic procedural protections are met. This decision upheld states' discretion over their own parole procedures while also affirming prisoners' limited due process rights.

In the dissenting opinion for Estelle, Corrections Director v. Dorrough, Justice William O. Douglas argued that the majority's decision was a violation of the Eighth Amendment's prohibition against cruel and unusual punishment. He contended that solitary confinement is an inhumane form of punishment due to its severe psychological effects on inmates. Furthermore, he disagreed with the majority’s view that it was not necessary for courts to review prison disciplinary actions unless they were arbitrary or capricious. In his view, this standard did not adequately protect prisoners' constitutional rights because it allowed prisons too much discretion in their use of punitive measures like solitary confinement without sufficient oversight from judicial authorities.