In the case of Smith v. Digmon, Warden, et al., 1977, the United States Supreme Court ruled in favor of petitioner Smith who had been denied habeas corpus relief by lower courts. The issue at hand was whether or not there was a full and fair hearing on his claim that evidence used against him in trial had been obtained illegally. The Alabama state court found no constitutional violation but did not explicitly address this specific claim made by Smith during post-conviction proceedings. This led to ambiguity about whether it had actually considered and rejected his argument or simply overlooked it entirely. The U.S Supreme Court held that when a federal constitutional claim is presented to a state court and the state court denies relief without clearly indicating that it has assessed and rejected such claims on their merits, then federal habeas review may be available despite any assertion of procedural default under state law. This ruling emphasized the importance for clarity from lower courts when addressing claims related to violations of constitutional rights so as not to deny defendants potential avenues for appeal.

In the dissenting opinion for Smith v. Digmon, Warden, et al., 1977, Justice Rehnquist argued that the majority's decision to grant habeas corpus relief was incorrect because it failed to respect the procedural rules of Alabama state courts. He contended that federal courts should not intervene in state court decisions unless there is a clear violation of constitutional rights or if state procedures are inadequate to protect those rights. In this case, he believed neither condition had been met. The petitioner had ample opportunity to raise his claims during his trial and on direct appeal but chose not to do so until filing for post-conviction relief at a later stage which was procedurally barred under Alabama law due its untimeliness. Therefore, according to Justice Rehnquist's view, granting habeas corpus relief undermined both federalism principles and comity between states and federal government by disregarding validly established local legal processes without sufficient justification.