In the 1992 case Willie Lee Richmond v. Samuel A. Lewis, Director, Arizona Department of Corrections et al., the U.S Supreme Court examined whether a state prisoner's claim for damages and declaratory relief was barred by his failure to exhaust administrative remedies before filing suit under 42 U.S.C §1983. The petitioner, Willie Lee Richmond, an inmate in an Arizona prison filed a lawsuit against prison officials alleging that they had violated his Eighth Amendment rights by subjecting him to cruel and unusual punishment through inadequate medical care. However, he did not first seek redress through the state’s established grievance procedure as required by law. The court held that there is no requirement for prisoners to exhaust all available administrative remedies before bringing a §1983 action seeking monetary damages; hence it ruled in favor of Richmond stating that exhaustion of such remedies is not a prerequisite for action under Section 1983 which provides recourse for violations of constitutional rights.

In the dissenting opinion for Willie Lee Richmond v. Samuel A. Lewis, Director, Arizona Department of Corrections et al., Justice Blackmun argued that the majority's decision was a departure from established precedent and an unnecessary restriction on habeas corpus relief. He contended that the Court had previously held that procedural default rules should not bar federal review unless they are consistently or regularly applied by state courts. In this case, he believed there was clear evidence to suggest inconsistency in application of such rules by Arizona courts which should have allowed for federal review of Richmond’s claim under habeas corpus proceedings. Furthermore, he criticized the majority's reliance on Teague v Lane as misplaced since it did not involve a situation where state law provided no opportunity at all for defendant to raise his constitutional claim before trial court or on direct appeal.