In the case of Paterno v. Lyons, Commissioner of Correction in 1947, Joseph Paterno was convicted for murder and sentenced to death by electrocution. He appealed his sentence on the grounds that it violated his constitutional rights under the Eighth Amendment's prohibition against cruel and unusual punishment. The U.S Supreme Court rejected this argument, ruling that execution by electrocution did not constitute cruel or unusual punishment as defined by the Constitution. Furthermore, they stated that such a method had been deemed acceptable since its first use in 1890 and noted that many states used this form of capital punishment at the time. Therefore, Paterno's claim was dismissed and his conviction upheld.

The dissenting opinion in the case of Paterno v. Lyons, Commissioner of Correction argued that the majority's decision was a departure from established principles and precedent regarding habeas corpus petitions. The dissent emphasized that it is not within the purview of federal courts to reevaluate state court decisions on matters of fact or law unless there has been an egregious violation of constitutional rights. In this case, they believed no such violation had occurred; rather, they saw it as a disagreement with how New York courts interpreted their own laws concerning insanity pleas and criminal responsibility. They expressed concern about potential overreach by federal judges into state legal affairs and cautioned against setting a dangerous precedent where every unsuccessful litigant in state court could seek redress through federal habeas corpus proceedings based on perceived errors or injustices at the state level.