In the case of Remon Lee v. Mike Kemna, Superintendent, Crossroads Correctional Center (2001), the U.S Supreme Court addressed issues related to habeas corpus petitions and procedural default rules. The petitioner, Remon Lee was a Missouri state prisoner who had missed his deadline for filing an appeal in state court due to alleged attorney negligence. He then filed a federal habeas corpus petition challenging his conviction on constitutional grounds but it was dismissed by lower courts as procedurally defaulted because he failed to exhaust all available state remedies first before seeking federal relief. The Supreme Court held that even if there is cause for a procedural default (in this case, ineffective assistance of counsel), federal courts are not required to hear claims that have been defaulted in state court unless the defendant can show actual prejudice resulting from the errors claimed or demonstrate that failure to consider these claims will result in a fundamental miscarriage of justice. This decision reinforced strict adherence to exhaustion requirements and emphasized states' rights over their own criminal procedures while limiting opportunities for prisoners like Lee who seek post-conviction relief through federal habeas review.

In the dissenting opinion for Remon Lee v. Mike Kemna, Justice Stevens argued that the majority's decision to deny habeas corpus relief was too rigid and failed to consider important factors in this case. He contended that there should be a more flexible approach when dealing with procedural default rules, especially when it involves fundamental constitutional rights such as ineffective assistance of counsel claim raised by Lee. He also criticized the majority's reliance on state court decisions which he believed were inconsistent and did not provide clear guidance on what constitutes "cause" for procedural default under Missouri law. Furthermore, he disagreed with their interpretation of federal laws governing habeas corpus petitions, arguing they misapplied these laws in a way that unfairly disadvantaged Mr. Lee who had diligently pursued his claims at every level of judicial review.