In the case of Finley, Clerk of the Circuit Court of Cook County, Illinois v. Murray (1981), the United States Supreme Court addressed whether a state court clerk could be held liable for damages under 42 U.S.C. § 1983 for failing to promptly forward an appeal notice to a higher court, resulting in dismissal of petitioner's appeal. The plaintiff argued that this delay violated his Fourteenth Amendment right to due process and access to courts. However, the Supreme Court ruled in favor of defendant Finley stating that he was protected by quasi-judicial immunity as his duties were closely associated with judicial proceedings and thus immune from liability under Section 1983 unless they acted in clear absence or excess their jurisdiction.

In the dissenting opinion for Finley v. Murray, Justice Brennan disagreed with the majority's decision to deny habeas corpus relief to a prisoner who had been convicted of murder and sentenced to death. He argued that the state court had violated the defendant's constitutional rights by failing to provide him with effective legal representation during his trial. Specifically, he pointed out that defense counsel did not present any mitigating evidence during sentencing phase which could have potentially spared him from death penalty. Furthermore, Justice Brennan criticized Illinois' capital punishment statute as being overly broad and vague in defining what constitutes an "aggravated" offense deserving of death penalty - thus violating Eighth Amendment prohibition against cruel and unusual punishments. He also expressed concern about racial disparities in application of capital punishment in Illinois, noting that black defendants were disproportionately likely to receive death sentences compared with white defendants charged with similar crimes.