The U.S. Supreme Court case William D. O'Sullivan v. Darren Boerckel, 1998 revolved around the issue of whether a federal habeas petitioner must present his claims to a state's highest court in order to satisfy the exhaustion requirement outlined in 28 U.S.C §2254(b)(1). The respondent, Darren Boerckel was convicted for murder and attempted rape by an Illinois trial court and sentenced to life imprisonment without parole. After exhausting all direct appeal options within the state courts, he filed a petition for post-conviction relief which was denied by both the trial court and appellate court but did not seek discretionary review from Illinois Supreme Court before filing his federal habeas corpus petition. The District Court dismissed some of his claims as unexhausted while others were rejected on their merits; however, it granted him certificate of probable cause (CPC) allowing him to appeal its decision regarding certain issues including ineffective assistance of counsel claim. On appeal, Seventh Circuit reversed district court’s dismissal stating that presentation at lower levels satisfied exhaustion requirement even if not presented before state's highest tribunal unless there is clear indication that such tribunal would consider it procedurally barred. However, US Supreme Court disagreed with this interpretation holding that full round of State’s established appellate review process must be completed thus reversing Seventh Circuit’s judgment.

In the dissenting opinion for William D. O'Sullivan v. Darren Boerckel, it was argued that the majority's decision to dismiss O'Sullivan's habeas corpus petition on procedural grounds went against established precedent and unfairly penalized him for failing to understand complex legal procedures. The dissent pointed out that previous Supreme Court rulings had allowed federal courts to hear habeas petitions even when state court remedies hadn't been exhausted if there were extenuating circumstances, such as a petitioner being unaware of certain procedural requirements due to lack of legal counsel or education. In this case, they believed O'Sullivan should have been given similar leeway since he filed his petition pro se (without an attorney) and may not have fully understood what he needed to do in order for his claims to be heard by a federal court.