In the case of Francisco v. Gathright, 1974, the petitioner, a state prisoner in Virginia, sought to challenge his conviction on constitutional grounds through habeas corpus proceedings. He claimed that he was denied effective assistance of counsel because his lawyer failed to object to certain evidence and did not adequately cross-examine witnesses during trial. The District Court dismissed his petition without holding an evidentiary hearing or appointing counsel for him. The Supreme Court held that it was error for the District Court not to have appointed counsel for Francisco before dismissing his petition since this violated due process rights under the Fourteenth Amendment. It also ruled that if there were factual disputes regarding whether Francisco's original attorney had provided ineffective assistance of counsel at trial, then an evidentiary hearing should be conducted by the court. This decision underscored two important principles: firstly, prisoners who cannot afford legal representation must be provided with one when challenging their convictions; secondly, courts are required to conduct hearings whenever there is a genuine dispute over facts related to claims made in habeas corpus petitions.

In the dissenting opinion for Francisco v. Gathright, 1974, Justice Douglas argued that the case should have been heard by the Supreme Court due to its implications on prisoner rights and constitutional law. He disagreed with the majority's decision to dismiss it as a habeas corpus petition without hearing oral arguments or fully reviewing briefs. The petitioner was an inmate who claimed his First Amendment rights were violated when he was placed in solitary confinement for attempting to form a union among prisoners. Justice Douglas believed this raised serious questions about freedom of speech and association within prisons, which deserved full consideration by the court. He also expressed concern over potential misuse of administrative segregation in prisons as punishment for constitutionally protected activities.