In the case of Procunier, Director, California Department of Corrections v. Atchley (1970), the U.S Supreme Court dealt with a petition for habeas corpus by an inmate who was convicted in 1952 and sentenced to death. The petitioner claimed that his constitutional rights were violated as he was denied access to certain documents during his trial which could have potentially affected its outcome. He also argued that he had ineffective assistance from counsel due to their failure to object against this denial or request for these documents at any point during the trial proceedings. The Supreme Court ruled in favor of Procunier, stating that while prisoners do have a right under the Due Process Clause to be provided with necessary tools for an adequate defense, it is not absolute and can be limited based on legitimate institutional needs or objectives such as security concerns within prisons. Furthermore, they found no evidence suggesting prejudice towards Atchley's defense due to lack of these materials nor did they find incompetence on part of his counsel since there wasn't enough proof indicating how possession of those records would've changed anything about his conviction.

In the dissenting opinion for Procunier v. Atchley, Justice William O. Douglas argued that the majority's decision to uphold restrictions on inmate correspondence violated First Amendment rights of free speech and expression. He contended that prisoners should not be denied their constitutional rights unless there is a compelling state interest at stake, which he did not believe was present in this case. Furthermore, he criticized the majority for failing to provide clear guidelines as to what constitutes permissible censorship by prison officials, thereby leaving room for potential abuse of power and arbitrary decisions about what inmates can or cannot say in their letters. In his view, such vagueness could lead to suppression of legitimate grievances against prison conditions or other forms of protest protected under the First Amendment.