The U.S. Supreme Court case Fay, Warden, et al. v. Noia in 1962 revolved around the issue of habeas corpus and its application to state court judgments under federal law. The respondent, Ernesto Miranda Noia was convicted for first-degree murder by a New York State court and sentenced to life imprisonment without parole; he claimed his confession had been coerced violating his constitutional rights but did not appeal this conviction at the state level due to fear of receiving death penalty on retrial if successful. Years later, after exhausting all state remedies available including an unsuccessful petition for writ of error coram nobis (a legal order allowing courts to correct their original judgment), Noia filed a petition for writ of habeas corpus in Federal District Court arguing that his detention violated U.S Constitution's Fourteenth Amendment which guarantees due process rights. In a landmark decision with far-reaching implications on criminal justice system, the Supreme Court ruled 5-4 in favor of Noia stating that federal courts have power under Habeas Corpus Act (28 USC §2241) to entertain applications from state prisoners who claim they are detained unconstitutionally even if they failed or deliberately bypassed any available remedies at the state level.

In the dissenting opinion for Fay v. Noia, Justice Harlan argued that federal courts should not have jurisdiction over state court convictions unless a defendant was denied a full and fair opportunity to litigate his constitutional claims in state court. He asserted that the majority's decision undermined principles of federalism by allowing defendants to bypass their opportunities for appeal in state courts and instead seek habeas corpus relief directly from federal courts. This, he believed, would lead to an unnecessary increase in litigation and undermine respect for finality of judgments. Furthermore, he contended that it is inappropriate for federal judges to second-guess decisions made by their counterparts at the state level when those decisions were based on reasonable interpretations of existing law.