In the 1980 case Jones, Warden, Stone Mountain Correctional Institution v. Helms, the U.S Supreme Court was tasked with determining whether a Georgia state prisoner's habeas corpus petition should be dismissed due to his failure to exhaust all available state remedies before filing in federal court. The petitioner had been convicted of rape and robbery but claimed that he was denied effective assistance of counsel during his trial. He filed for a writ of habeas corpus in federal district court without first seeking relief through Georgia's post-conviction procedures. The District Court dismissed his petition on grounds that he failed to exhaust all possible state remedies as required by law before resorting to federal courts. The Supreme Court held that while exhaustion is generally necessary under Section 2254(b) and (c), there are exceptions when circumstances render such processes ineffective or futile. In this particular case, however, it found no special circumstances justifying an exception from the requirement for exhaustion of state remedies prior to invoking federal jurisdiction over a habeas claim.

In the dissenting opinion for Jones v. Helms, Justice Brennan disagreed with the majority's decision to uphold a Georgia statute that allowed prison officials to withhold good time credits from inmates who refused to participate in rehabilitative programs. He argued that this policy violated prisoners' First Amendment rights by forcing them into religious activities against their will and was thus unconstitutional. Furthermore, he contended that the state had failed to demonstrate how such coercion served its interest in rehabilitation or public safety. The justice also criticized the majority for ignoring precedent set by previous cases which established strict scrutiny as the standard of review for laws infringing upon fundamental constitutional rights, including freedom of religion.