In the case of Swain, Reformatory Superintendent v. Pressley (1976), the United States Supreme Court ruled that federal prisoners do not have a constitutional right to file habeas corpus petitions in courts located where they are incarcerated. The petitioner, Pressley, was an inmate at a reformatory in Virginia who sought to challenge his transfer from Washington D.C., arguing it violated his Fifth Amendment rights and infringed upon his ability to access legal resources. However, the court held that while inmates may challenge their confinement conditions through civil rights actions under 42 U.S.C §1983 or other similar statutes, they cannot use habeas corpus as a means for such challenges unless it directly affects the fact or duration of their imprisonment. This decision clarified and limited the scope of prisoner's rights regarding filing locations for habeas corpus petitions.

In the dissenting opinion for Swain v. Pressley, Justice Brennan argued that the majority's decision was a significant departure from established habeas corpus jurisprudence. He contended that Congress did not intend to restrict federal prisoners' access to traditional habeas corpus relief when it enacted 28 U.S.C §2255 and disagreed with the majority’s interpretation of this statute as providing an adequate substitute for habeas corpus in all cases. Furthermore, he expressed concern about limiting judicial review of constitutional claims by incarcerated individuals, particularly those who may be innocent or wrongly convicted due to procedural errors at trial. In his view, such restrictions undermine public confidence in the justice system and erode fundamental protections against unlawful imprisonment.