The issue heard in the Supreme Court centered around a confession Townsend had given while under the influence of an alleged "truth serum".

Townsend appealed the case by filing a writ of habeas corpus against Sheriff Frank G. Sain of Cook County, Illinois.

Alongside Fay v. Noia and Sanders v. United States, Townsend is cited as revolutionizing and greatly expanding the use of habeas corpus, leading to it being used as a general purpose appeals tool.

[4][5] The original case went to trial in 1955 in the Circuit Court of Cook County, where Townsend was convicted of murder and sentenced to death.

Ordinarily such a record— including the transcript of testimony (or if unavailable some adequate substitute, such as a narrative record), the pleadings, court opinions, and other pertinent documents — is indispensable to determining whether the habeas applicant received a full and fair state-court evidentiary hearing resulting in reliable findings.

Of course, if because no record can be obtained the district judge has no way of determining whether a full and fair hearing which resulted in findings of relevant fact was vouchsafed, he must hold one.

So also, there may be cases in which it is more convenient for the district judge to hold an evidentiary hearing forthwith rather than compel production of the record.

[6][14] The Supreme Court said such factual determinations could be relitigated at a federal hearing if the state fact-finding procedure was not adequate for reaching "reasonably correct results":[12] Even if all the relevant facts were presented in the state-court hearing, it may be that the fact-finding procedure there employed was not adequate for reaching reasonably correct results.

Even where the procedure employed does not violate the Constitution, if it appears to be seriously inadequate for the ascertainment of the truth, it is the federal judge’s duty to disregard the state findings and take evidence anew.Additionally the court noted that the medical expert for the prosecution had made a mistake by not noting in layman's terms the fact that hyoscine could possibly act as a truth serum.

[16] However the court was careful to avoid actually determining whether the drug in question was in fact a truth serum, or if the confession had been the result of it.

[11] The Supreme Court in Keeney v. Tamayo-Reyes (1992) had already overturned part of Townsend that requiring a meaningful opportunity for fact development in cases where counsel had been negligent or incompetent in the state proceedings.

Keeney established that prisoners must show cause for procedural default, even if the "material facts were not adequateley developed at the state-court hearing".

[19] Keeney was part of an attempt to streamline the overburdened appeals process, since at the time more than 10,000 habeas corpus requests were filed every year, many of which were frivolous, accounting for almost 5% of all civil cases in federal court.

Commentators Bloom and Brodin suggest this is a "revisionist reading" since the officers apparently did not know about the administration of drugs to Townsend.