In the case of Sanders v. United States (1962), the U.S. Supreme Court ruled that a defendant can file multiple habeas corpus petitions, even if they are based on similar grounds as previous ones, provided new evidence or arguments are presented. The petitioner, Sanders was serving two concurrent sentences for bank robbery and murder when he filed his third petition for writ of habeas corpus challenging his detention's legality. His first two petitions were denied without hearing because they did not present any constitutional issues about his conviction or sentence validity. However, in this third petition, he claimed that he had been denied effective assistance of counsel during trial which constituted a violation of due process under the Fourteenth Amendment to the Constitution - an issue not raised in prior applications. The court held that controlling weight may be given to denial of a prior application for federal habeas corpus only if: (1) same ground presented in subsequent application was determined adversely to applicant on prior application; (2) prior determination was on merits; and (3) ends-of-justice would not be served by reaching merits of subsequent application.

In the dissenting opinion for Sanders v. United States, Justice Harlan argued that the majority's decision to allow a federal prisoner to file multiple habeas corpus petitions undermines the finality of criminal judgments and disrupts prison administration. He contended that this ruling would encourage prisoners to continually challenge their convictions or sentences, leading to an excessive burden on courts and prison officials. Furthermore, he disagreed with the majority's interpretation of Section 2255 as allowing unlimited applications for relief; instead, he believed it should be read in conjunction with other laws governing post-conviction remedies which limit such filings unless there is new evidence or a change in law. In his view, this approach would strike a better balance between protecting individual rights and maintaining judicial efficiency.