In the case of United States v. Jacob Denedo, the Supreme Court ruled in favor of Denedo, an immigrant who had served in the U.S Navy and was facing deportation due to a conviction for larceny. The court held that it had jurisdiction over his petition for habeas corpus challenging his conviction on grounds of ineffective assistance of counsel during his trial at a military court-martial. His lawyer failed to advise him about potential immigration consequences which led to his deportation proceedings years after he completed probation. This ruling marked a significant development as it recognized that military courts have equal responsibility as civilian courts under federal law to hear claims related to wrongful convictions or sentences even after direct review within the military system is exhausted.

In the dissenting opinion for United States v. Jacob Denedo, Justice Scalia argued that the majority had expanded the scope of habeas corpus relief in a way that was inconsistent with historical practice and precedent. He contended that military courts should have exclusive jurisdiction over cases involving military personnel, as civilian interference could undermine military discipline and morale. Furthermore, he disagreed with the majority's interpretation of "in custody" requirement for habeas corpus petitions; according to him, this requirement cannot be met once an individual has been discharged from service because they are no longer under any form of physical or legal restraint imposed by their sentence. Therefore, Denedo's discharge from Navy made his petition ineligible for consideration under federal habeas statute. Lastly, he criticized the majority’s decision to allow claims based on ineffective assistance of counsel in collateral review proceedings before Courts-Martial Review Boards as it goes beyond what Congress intended when it established these boards.