Since 1867, state prisoners had the ability to seek habeas corpus relief from a federal court. Noia was convicted in New York state court of felony murder but could not seek post-conviction relief from the state appellate court because he had failed to appeal in time. The U.S. district court denied Noia’s petition for a writ of habeas corpus, ruling that the writ was not available in a case where the petitioner had failed to exhaust all available state remedies. The U.S. court of appeals reversed, holding that the state remedy was no longer available at the time the habeas corpus proceeding was commenced. The Supreme Court affirmed on the basis that a procedural default in state court, which would have barred direct review of the case, did not bar a collateral review via a writ of habeas corpus. The decision was part of a trend lasting from the 1940s to the 1960s in which the Court expanded the rights of state prisoners to seek habeas relief in federal courts and expanded federal court power over state court convictions. As a result, many more state prisoners began to challenge their detention in the U.S. district courts. In the late 1960s, the Court began to retreat from its expansion of habeas corpus, and in its 1991 decision in Coleman v. Thompson, the Court overturned its decision in Fay.