In the case of Holder v. Banks, 1973, the U.S. Supreme Court dealt with a dispute over whether or not federal courts could review state court decisions in habeas corpus proceedings involving constitutional rights claims that had been fully and fairly adjudicated by state courts. The petitioner was a district judge who sought to prevent such reviews while respondent was an inmate seeking relief from his conviction on grounds of alleged constitutional violations during his trial. The Supreme Court held that federal courts do have authority to review state court decisions in these circumstances under certain conditions but also emphasized deference towards prior adequate and independent state court determinations on federal constitutional questions unless there is cause for procedural default and actual prejudice resulting from it.

In the dissenting opinion for Holder v. Banks, it was argued that the majority's decision to uphold a lower court ruling against an Alabama law requiring state employees to take loyalty oaths violated constitutional principles. The dissenters believed that such oaths were not inherently unconstitutional and could serve as legitimate tools in protecting national security interests. They also disagreed with the majority's interpretation of previous Supreme Court rulings on similar issues, arguing that these cases did not establish a blanket prohibition on loyalty oaths but rather required them to be narrowly tailored and directly related to specific government interests. Furthermore, they contended that by invalidating Alabama’s oath requirement without considering its particular context or purpose, the Court had overstepped its judicial authority and encroached upon states' rights.