In Kaufman v. United States (1968), the U.S Supreme Court ruled that federal prisoners have a constitutional right to challenge their convictions in federal court, even after they've exhausted all of their state remedies. The case involved Irving Kaufman, who was convicted for murder in New York and sought habeas corpus relief from his conviction on the grounds that he had been denied effective assistance of counsel during his trial. His petition was initially dismissed by lower courts on procedural grounds but was eventually granted by the Supreme Court which held that Section 2255 does not bar a prisoner from applying for a writ of habeas corpus when it appears that justice will not be served by following regular procedure. This decision significantly expanded access to post-conviction relief for individuals convicted in state courts.

In the dissenting opinion for Kaufman v. United States, Justice Harlan argued that federal courts should not have jurisdiction to review state court convictions on constitutional grounds through habeas corpus petitions unless there is a showing of exceptional circumstances. He believed that such reviews undermine the finality of state court judgments and disrupt the balance between federal and state judicial responsibilities. The majority's decision, according to him, would lead to an increase in frivolous claims by prisoners seeking release from custody or other relief based on alleged violations of their constitutional rights during their trials. This could potentially burden federal courts with cases better handled at the state level and delay justice for victims of crime. Furthermore, he contended that this broad interpretation was inconsistent with historical practice and understanding regarding habeas corpus proceedings.