In the case of Lavallee, Correctional Superintendent v. Delle Rose in 1972, the U.S Supreme Court was asked to consider whether a state could constitutionally imprison an individual who had been civilly committed for alcoholism but had not received treatment during his confinement. The petitioner, Lavallee, argued that such imprisonment violated the Eighth Amendment's prohibition on cruel and unusual punishment as well as due process rights under the Fourteenth Amendment. However, before reaching a decision on these issues, it was discovered that Delle Rose had been released from prison making his appeal moot. As a result of this development and following established legal principles regarding mootness (the idea that courts will only decide actual controversies), the Supreme Court dismissed Delle Rose’s petition without ruling on its merits.

In the case of Lavallee, Correctional Superintendent v. Delle Rose (1972), Justice William O. Douglas dissented from the majority opinion. He argued that the petitioner's constitutional rights were violated when he was denied access to a transcript of his trial for purposes of appeal due to his inability to afford it. The denial, according to Justice Douglas, constituted discrimination against poor defendants and undermined their right to equal protection under law as guaranteed by the Fourteenth Amendment. He contended that justice should not be dependent on one's financial status or ability but rather should be equally accessible for all citizens regardless of wealth or poverty.