In Ralston, Warden v. Robinson (1981), the U.S. Supreme Court examined whether a state prisoner's rights were violated under the Equal Protection Clause of the Fourteenth Amendment when he was denied parole due to his inability to participate in Alcoholics Anonymous (AA) meetings because they weren't offered at his prison facility. The petitioner, Robinson, argued that prisoners at other facilities who had access to AA meetings were more likely to be granted parole and thus he was being discriminated against based on his place of incarceration. However, the court ruled against him stating that there is no constitutional right for a prisoner to participate in any particular rehabilitative program while incarcerated and therefore there was no violation of equal protection rights as all inmates are subjectively evaluated for parole based on their individual circumstances.

In the dissenting opinion for Ralston, Warden v. Robinson, Justice Rehnquist argued that the majority's decision to remand the case back to lower courts was unnecessary and overly cautious. He contended that there was no need for further fact-finding because it was clear from existing records that Robinson had been adequately informed of his rights before making incriminating statements during a psychiatric evaluation. Furthermore, he disagreed with the majority's interpretation of Estelle v. Smith (1981), arguing instead that this precedent did not automatically require Miranda warnings prior to such evaluations in all cases involving potential death sentences. Instead, he believed these warnings were only necessary when an examination is conducted solely for gathering evidence against a defendant rather than assessing their competency or mental state at sentencing.