In the case of Hughes v. Rowe et al., 1980, the United States Supreme Court ruled in favor of a prisoner who had filed a civil rights lawsuit against prison officials. The plaintiff, Hughes, alleged that his constitutional rights were violated by these officials while he was incarcerated at Illinois State Penitentiary. However, his complaint was dismissed by lower courts without any hearing or opportunity for him to present evidence supporting his claims. The Supreme Court reversed this decision and remanded the case back to district court for further proceedings. It held that unless it is absolutely clear from an inmate's allegations that no viable claim exists under established legal principles, then dismissal should not occur until parties have been given an opportunity to present their cases through evidentiary hearings or other appropriate procedures.

In the dissenting opinion for Hughes v. Rowe et al., Justice William Rehnquist disagreed with the majority's decision to reverse and remand the case back to District Court. He argued that there was no need for further proceedings because it was clear from existing records that Hughes' claim had no merit, as determined by both a Magistrate and District Judge who reviewed his complaint in detail. The dissent emphasized that while pro se complaints are held to less stringent standards than formal pleadings drafted by lawyers, they must still present a plausible legal claim upon which relief could be granted. In this case, according to Justice Rehnquist, Hughes failed to meet even this minimal requirement since he did not provide any specific facts supporting his allegations of racial discrimination or conspiracy against him by prison officials; rather he made only vague and conclusory statements without any factual basis.