In Patterson v. Alabama (1934), the U.S Supreme Court ruled that an African American defendant, Haywood Patterson, was denied his right to a fair trial because of racial discrimination in jury selection. The case arose from the infamous "Scottsboro Boys" trials where nine young black men were falsely accused of raping two white women on a train in 1931. Despite lack of evidence and one accuser recanting her testimony, all-white juries convicted eight defendants with death sentences. On appeal to the Supreme Court, it was argued that Alabama's exclusionary practices violated equal protection under the Fourteenth Amendment by systematically excluding blacks from serving as jurors. The court agreed and overturned Patterson's conviction due to violation of his constitutional rights for impartial jury selection process free from racial bias.

In the dissenting opinion for Patterson v. Alabama, Justice McReynolds argued that the Supreme Court did not have jurisdiction to review state court decisions based on federal questions unless those issues were properly raised and decided in state courts first. He contended that the defendants had failed to raise their Fourteenth Amendment claims during their trial or appeal in Alabama's courts, thus they could not bring these arguments before the Supreme Court. Furthermore, he believed that even if such a claim had been made at an earlier stage of proceedings, it would still be inappropriate for this court to intervene as there was no clear evidence of prejudice against African Americans in jury selection within this specific case. The justice also expressed concern about setting a precedent where every criminal defendant who is dissatisfied with his trial might attempt to seek redress from the U.S Supreme Court by claiming constitutional violations.