The Supreme Court case Woodard, Secretary of Corrections of North Carolina, et al. v. Hutchins (1983) revolved around the issue of whether a prisoner's constitutional rights were violated when he was denied access to an attorney during his parole hearing. The petitioner, Hutchins, argued that without legal representation at these hearings, prisoners are unable to adequately defend themselves or present their cases for parole effectively. However, the court ruled against him in a 5-4 decision stating that there is no constitutional right for inmates to have counsel present during parole hearings because they are not considered adversarial proceedings under law and therefore do not require the same protections as criminal trials do such as having an attorney present.

In the dissenting opinion for Woodard v. Hutchins, Justice Brennan, joined by Justices Marshall and Blackmun, argued that the majority's decision to deny a stay of execution was incorrect due to unresolved questions about whether or not death row inmates have a constitutional right to post-conviction relief. The dissenters believed that these issues were significant enough to warrant further review before an execution could proceed. They also expressed concern over the potential violation of Eighth Amendment protections against cruel and unusual punishment if executions were allowed while such legal uncertainties remained unaddressed. Furthermore, they criticized their colleagues' reliance on procedural grounds rather than addressing substantive constitutional claims raised by Hutchins in his appeal.