In the case of Rose, Warden v. Lundy (1981), the U.S Supreme Court ruled that federal courts must dismiss habeas corpus petitions that contain both exhausted and unexhausted claims - a doctrine known as "total exhaustion requirement". The petitioner, Robert Lundy, was convicted in Tennessee state court for first-degree murder and sentenced to life imprisonment. He filed a petition for writ of habeas corpus in Federal District Court claiming his constitutional rights were violated during trial but did not exhaust all available state remedies before filing this petition. The district court dismissed his application without prejudice so he could return to state court to exhaust all remedies. On appeal, the Sixth Circuit reversed this decision arguing partial merits review should be allowed on those issues already exhausted at the time of filing federal habeas corpus petitions while holding other issues pending until they are fully exhausted at state level. However, when appealed to Supreme Court it held that under 28 USC Section 2254(b) which governs applications for writ of habeas corpus by persons in custody pursuant to judgment of State Courts; if any claim is not fully exhausted then entire application must be dismissed.

In the dissenting opinion for Rose v. Lundy, Justice Blackmun argued that the majority's decision to require total exhaustion of state remedies before a federal habeas corpus petition can be filed was overly rigid and could potentially lead to unnecessary delays in resolving prisoners' claims. He noted that this approach would force inmates who had exhausted some but not all of their claims to return to state court, which might take years before they could refile in federal court. This delay, he suggested, did not serve any significant interest and only served as an impediment for those seeking relief from unlawful imprisonment. Furthermore, he pointed out that there were other ways for courts to manage mixed petitions without requiring complete exhaustion such as staying proceedings on unexhausted claims while allowing exhausted ones proceed or dismissing unexhausted claims with leave granted for them being added back once they are exhausted at the state level.