In the case of Hunter, Warden v. Martin in 1947, the United States Supreme Court ruled on a matter involving habeas corpus and jurisdictional issues. The respondent, Martin had been convicted for murder in Virginia state court and sentenced to death. He appealed his conviction up to the U.S Supreme Court but was denied review. Subsequently, he filed a petition for habeas corpus in federal district court claiming that his constitutional rights were violated during his trial because African Americans were excluded from both grand jury and petit jury service due to their race. The District Court dismissed this petition stating it lacked jurisdiction since there was no evidence showing that these claims had been presented before or considered by any Virginia state courts as required by law at that time. On appeal however, the Fourth Circuit reversed this decision arguing that such racial discrimination constituted an exceptional circumstance which allowed bypassing of normal procedural requirements. Upon reaching the US Supreme Court though, it held (in a 5-4 decision) that federal courts did not have authority under existing laws to issue writs of habeas corpus unless all available remedies within state judicial systems including appeals had been exhausted first.

In the dissenting opinion for Hunter v. Martin, Justice Frankfurter disagreed with the majority's decision to overturn a lower court ruling that had denied habeas corpus relief to a prisoner convicted of murder. He argued that the Supreme Court should not have intervened in this case because it involved state law issues and was therefore outside its jurisdiction. Furthermore, he believed that there were no federal constitutional questions at stake in this case as claimed by the petitioner. The justice also expressed concern about potential negative consequences of such intervention on federal-state relations and cautioned against overstepping boundaries set by principles of federalism.