In the case of Pinto, Prison Farm Superintendent v. Pierce (1967), the U.S Supreme Court addressed a dispute over whether an inmate could be punished for refusing to work while in prison. The petitioner, Pinto, argued that he had authority under New Jersey law to punish inmates who refused to perform assigned labor tasks. On the other hand, respondent Pierce contended that such punishment violated his constitutional rights against involuntary servitude as protected by the Thirteenth Amendment. The court ruled in favor of Pinto and held that compulsory labor within prisons did not constitute involuntary servitude prohibited by the Thirteenth Amendment; rather it was part of a prisoner's sentence and served as a means for rehabilitation and maintaining discipline within correctional facilities.

In the dissenting opinion for Pinto v. Pierce, Justice Douglas argued that a prisoner's right to access courts should not be limited by their ability to pay court fees. He believed that the majority ruling effectively barred indigent prisoners from seeking legal redress, which he saw as an infringement on their constitutional rights. Furthermore, he disagreed with the majority's interpretation of previous case law and felt they had misapplied it in this instance. In his view, all citizens have a fundamental right to petition courts for grievances regardless of their financial status or incarceration state.