The Ex Parte Hudgings case in 1918 involved a petitioner, Hudgings, who was held in custody by the United States Marshal for refusing to answer certain questions during his testimony before a Grand Jury. The Supreme Court had to decide whether he could be compelled to answer these questions. The court ruled that since the grand jury's investigation was within its jurisdiction and the questions were pertinent, Hudgings did not have any justifiable reason for refusal. Therefore, it upheld his detention until such time as he agreed to comply with the order of court and testify fully concerning all matters about which he might be interrogated before the grand jury.

In the dissenting opinion for Ex Parte Hudgings, it was argued that the petitioner should have been granted a writ of habeas corpus. The dissenting justices believed that Hudgings' constitutional rights were violated when he was denied access to counsel during his trial in state court. They contended that this denial constituted an infringement on his Sixth Amendment right to assistance of counsel and Fourteenth Amendment right to due process under law. Furthermore, they disagreed with the majority's view that federal courts lacked jurisdiction over such matters; instead, they asserted these courts could intervene if a person’s constitutional rights were being violated by state action. Thus, according to them, Hudgings should have been allowed relief through federal habeas corpus proceedings because his imprisonment resulted from unconstitutional procedures at the state level.