In the 1972 case of Preiser, Correction Commissioner, et al. v. Rodriguez et al., the U.S Supreme Court held that state prisoners who sought to challenge their continued confinement and wanted an immediate or speedier release must use habeas corpus remedies instead of filing a civil rights action under Section 1983. The plaintiffs were three New York State prison inmates who had lost good-conduct-time credits due to disciplinary actions and filed suit in federal court against corrections officials for restoration of these credits without exhausting state judicial remedies first. They argued that they were entitled to bring this claim under Section 1983 as it was a violation of their Fourteenth Amendment due process rights. However, the Supreme Court disagreed with this argument stating that Congress intended habeas corpus proceedings to be the exclusive remedy for such claims by state prisoners.

In the dissenting opinion for Preiser v. Rodriguez, Justice William O. Douglas argued that federal courts should have jurisdiction over state prisoner petitions challenging the duration of their confinement due to constitutional violations. He contended that habeas corpus was not exclusively designed for immediate release from unlawful imprisonment but could also be used to challenge conditions affecting the length of a sentence or parole decisions. The majority's decision, he believed, would force prisoners into lengthy and complex civil rights litigation instead of using straightforward habeas corpus procedures. Furthermore, he expressed concern about leaving such important issues solely in the hands of state courts without any federal oversight or review mechanism.