In the case of Shakur Muhammad, also known as John E. Mease, versus Mark Close in 2003, Muhammad filed a petition against Close for alleged violation of his constitutional rights under the Eighth Amendment. The petitioner claimed that he was subjected to cruel and unusual punishment while incarcerated at Potosi Correctional Center where Close served as an officer. Specifically, he argued that his health was endangered due to exposure to environmental tobacco smoke (ETS) from other inmates' cigarettes despite having a medical condition making him sensitive to such exposure. However, the court ruled in favor of defendant Mark Close stating there wasn't enough evidence proving deliberate indifference on part of prison officials towards Muhammad's serious medical needs or sufficient proof showing unreasonable risk posed by ETS levels inside prison cells.

The dissenting opinion in the case of Shakur Muhammad, aka John E. Mease v. Mark Close argued that the majority's decision to deny habeas corpus relief was incorrect due to a misinterpretation of federal law and precedent regarding ineffective assistance of counsel claims. The dissent believed that Muhammad’s trial attorney failed to provide effective representation by not objecting to certain evidence and failing to adequately cross-examine key witnesses, which could have significantly impacted the outcome of his trial. They also disagreed with the majority's conclusion that these errors were harmless beyond a reasonable doubt, arguing instead that they undermined confidence in the verdict and thus warranted a new trial for Muhammad.