The U.S. Supreme Court case Wainwright, Corrections Director, et al. v. Stone et al., 1973 revolved around the issue of whether a state prisoner could file a federal habeas corpus petition to challenge his conviction on grounds that were not raised in his initial appeal within the state court system but were permissible under new rules established by subsequent Supreme Court decisions. The petitioner was convicted for robbery and sentenced to life imprisonment in Florida State Courts without raising any constitutional claims during his trial or direct review process. After exhausting all available remedies within the state judicial system, he filed a federal habeas corpus petition claiming that certain evidence used against him at trial violated newly established Fourth Amendment protections as per recent Supreme Court rulings. The District Court dismissed this claim stating it had been procedurally defaulted since it wasn't raised initially during trial or direct review process while the Appeals court reversed this decision citing "cause and prejudice" standard which allowed such claims if defendant can show good cause for failing to raise them earlier and actual prejudice resulted from errors. However, upon reaching the Supreme Court, they ruled in favor of Wainwright (Corrections Director) holding that unless there is an adequate and independent finding of procedural default by last state court rendering judgment on matter; Federal Habeas Corpus relief would be unavailable even if 'cause-and-prejudice' test was met.

In the dissenting opinion for Wainwright v. Stone, Justice William O. Douglas argued that the majority's decision was a departure from established precedent regarding habeas corpus petitions and federal review of state court decisions. He contended that the Court had previously held that federal courts could review state court judgments when they involved constitutional issues, even if those issues were not raised in state court proceedings. In this case, he believed that Stone's Sixth Amendment right to effective counsel was violated because his lawyer did not object to an unconstitutional jury instruction at trial. Therefore, he felt it should be reviewed by a federal court despite being procedurally defaulted in state courts due to lack of objection during trial or on appeal therefrom.