In the 1933 case Ex Parte Baldwin et al., the U.S. Supreme Court dealt with a dispute over whether federal courts had jurisdiction to issue writs of habeas corpus for state prisoners who claimed their detention was in violation of federal law. The petitioners, Baldwin and others, were convicted under California's Criminal Syndicalism Act for membership in an organization advocating criminal syndicalism. They argued that this violated their First Amendment rights to freedom of speech and assembly as well as due process under the Fourteenth Amendment. The court ruled against them, stating that they should have raised these constitutional issues during their trial or on direct appeal within the state judicial system before seeking relief from a federal court. This decision reinforced principles of comity between state and federal courts by emphasizing respect for final judgments made by state courts when those judgments do not blatantly disregard or violate fundamental constitutional protections.

In the dissenting opinion for Ex Parte Baldwin et al., 1933, it was argued that the majority's decision to uphold a lower court ruling denying habeas corpus relief to petitioners convicted of murder and sentenced to death was incorrect. The dissenting justices believed that there were serious issues with how the trial had been conducted, including allegations of racial bias in jury selection and prosecutorial misconduct. They also took issue with the fact that one petitioner's confession had been used against all three defendants, despite evidence suggesting it may have been coerced. Furthermore, they disagreed with the majority's assertion that these issues could not be raised on habeas review because they had not been properly preserved at trial or on direct appeal. In their view, this approach failed to take into account systemic problems within Alabama’s criminal justice system during this period which made it difficult for African American defendants like those in this case to receive fair trials.