In the case of Rundle, Correctional Superintendent v. Johnson in 1966, the U.S Supreme Court examined whether a state prisoner's petition for habeas corpus was rightfully dismissed without an evidentiary hearing. The petitioner, Johnson, claimed that his constitutional rights were violated during his trial because he was denied effective assistance of counsel and had been coerced into pleading guilty by police officers' threats to arrest and charge his wife if he did not confess. The District Court dismissed the petition without holding an evidentiary hearing on these claims. The Supreme Court held that it was error to dismiss Johnson's application for habeas corpus relief without affording him a full and fair evidentiary hearing on his allegations. This decision emphasized that when a prisoner alleges facts which if true would entitle him to relief then federal courts must grant an evidentiary hearing unless the files and records conclusively show that he is entitled to no relief.

In the dissenting opinion for Rundle v. Johnson, Justice Douglas argued that the majority's decision was a departure from established precedent regarding habeas corpus petitions. He contended that Johnson had been denied his constitutional right to counsel during his trial and thus deserved a new one. The justice criticized the majority for not considering whether or not there was harmless error in this case, as they would have done if it were a direct appeal rather than a habeas corpus petition. Furthermore, he expressed concern about how this ruling could potentially limit federal courts' ability to protect individuals' constitutional rights in future cases involving state prisoners.