In the 1985 case of Murray, Director, Virginia Department of Corrections v. Carrier, the U.S. Supreme Court addressed whether a federal habeas corpus petitioner who has failed to abide by state procedural rules can still have his constitutional claims heard in federal court if he alleges that his attorney was ineffective for failing to raise those claims at trial or on appeal. The Court held that an allegation of ineffective assistance could constitute "cause" for a default only if the claim itself had some merit and was not procedurally barred under state law. Furthermore, it ruled that even when there is no cause shown for a procedural default, a federal habeas court may still hear claims defaulted in state court if failure to consider them would result in miscarriage of justice due to actual innocence.

In the dissenting opinion for Murray, Director, Virginia Department of Corrections v. Carrier (1985), Justice Stevens argued that the majority's decision to deny habeas corpus relief was unjustified and overly harsh. He contended that there should be a distinction between cases where defense counsel made an error in strategy versus those where they failed to present any strategy at all due to negligence or incompetence. In this case, he believed it fell into the latter category as Carrier’s attorney did not make a strategic choice but rather overlooked key evidence which could have potentially changed the outcome of his trial - specifically, testimony from two witnesses who would have corroborated Carrier's alibi. Justice Stevens also criticized the majority for their rigid interpretation of "cause" under procedural default rules and suggested more flexibility when considering whether defendants had adequate representation during their trials.