In the case of Willingham, Warden, et al. v. Morgan in 1968, the U.S Supreme Court ruled in favor of a prisoner's right to access federal courts for habeas corpus petitions without first exhausting state remedies if state officials had not followed their own procedures correctly. The petitioner was an inmate at Washington State Penitentiary who filed a writ of habeas corpus alleging that he was being held unlawfully because his constitutional rights were violated during his trial and sentencing process. He claimed that he did not have adequate legal representation and that there were errors made by the court during his trial proceedings which resulted in an unfair conviction. The District Court dismissed his petition on grounds that he had failed to exhaust all available state remedies before seeking federal relief as required under existing law (28 U.S.C §2254). However, upon appeal, the Ninth Circuit reversed this decision stating it wasn't necessary for him to exhaust these remedies since they weren't effective or accessible due to procedural default by state officials. The Supreme Court affirmed this ruling emphasizing on principles of comity and federalism where Federal Courts should respect State Courts but also ensure protection against violation of Constitutional Rights.

In the dissenting opinion for Willingham, Warden, et al. v. Morgan (1968), Justice Harlan disagreed with the majority's view that a state prisoner could sue his jailer in federal court under 28 U.S.C § 1343(3) without exhausting available state judicial remedies first. He argued that this interpretation of Section 1983 was inconsistent with its legislative history and prior Supreme Court decisions which required exhaustion of state remedies before resorting to federal courts except in special circumstances where such remedies were inadequate or unavailable. Furthermore, he expressed concern about the potential floodgate effect this decision might have on federal courts being inundated by lawsuits from prisoners challenging every aspect of their confinement conditions and treatment by prison officials - matters traditionally within states' jurisdiction and expertise to handle appropriately through their own legal systems.