In the case of John Marshall, Warden v. Otis Lee Rodgers in 2012, the U.S. Supreme Court ruled that an inmate does not have a constitutional right to effective assistance of counsel when filing for habeas corpus relief from administrative decisions made within prison systems. The petitioner, Otis Lee Rodgers, was an inmate who had been denied parole and sought to challenge this decision through a federal habeas petition. He claimed his attorney's failure to meet a filing deadline constituted ineffective assistance of counsel under the Sixth Amendment - which guarantees defendants legal representation in criminal prosecutions - thus violating his rights and entitling him to relief from the denial of parole. However, because he was no longer facing criminal prosecution but challenging an administrative decision instead (the denial of parole), it fell outside Sixth Amendment protections as per previous rulings by SCOTUS.

In the dissenting opinion for John Marshall, Warden v. Otis Lee Rodgers, Justice Breyer argued that the majority's decision to deny Rodgers' habeas corpus petition was incorrect because it failed to consider whether his claim had merit. He believed that a federal court should have been able to hear Rodger’s ineffective assistance of counsel claim even though he did not raise this issue in his initial state post-conviction review proceeding. According to him, there were reasonable grounds for excusing any procedural default on Rodger's part due to potential deficiencies in his legal representation and mental health issues which could have affected his ability to properly present claims during earlier proceedings. Thus, he disagreed with the majority’s strict interpretation of procedural rules over considerations of fairness and justice.