In the case of Leeke, Director of South Carolina Department of Corrections, et al. v. Timmerman et al., 1981, the U.S Supreme Court addressed an issue related to prisoner rights and access to legal counsel. The respondents were inmates who filed a lawsuit against prison officials for allegedly interfering with their right to confidential communication with their attorneys by opening their legal mail outside of their presence. The District Court ruled in favor of the prisoners and issued an injunction prohibiting such actions by prison officials in future cases involving attorney-client correspondence. However, on appeal, the Supreme Court reversed this decision stating that there was no constitutional violation as long as there was no evidence showing that prison authorities had intentionally opened mail from attorneys in order to discover its contents or interfere with inmate's right to counsel. It held that while prisoners have a First Amendment right to send and receive mail, these rights can be limited by reasonable security measures taken by prisons including inspection procedures for incoming mails.

In the dissenting opinion for Leeke, Director of South Carolina Department of Corrections, et al. v. Timmerman et al., Justice William Brennan disagreed with the majority's decision to reverse a lower court ruling that had granted habeas corpus relief to an inmate who was denied access to legal assistance during his disciplinary hearing in prison. He argued that prisoners should have a constitutional right to counsel at such hearings because they are often ill-equipped to represent themselves effectively against trained correctional officers and administrators. Furthermore, he contended that denying inmates this right could lead them being unfairly punished or losing their good-time credits which would extend their time in prison without due process of law.