In the case of Bill K. Wilson, Superintendent, Indiana State Prison v. Joseph E. Corcoran in 2010, the U.S Supreme Court ruled on a habeas corpus petition from an inmate sentenced to death by an Indiana court for four counts of murder. The Seventh Circuit had granted relief based on its belief that the jury instructions at trial violated Corcoran's Sixth Amendment rights because they allowed jurors to recommend a death sentence without unanimous agreement as to any particular aggravating circumstance justifying it. However, the Supreme Court vacated this decision and remanded it back to lower courts for further consideration in light of Smith v Spisak (2009). In Spisak’s case, similar jury instructions were found not unconstitutional since they did not prevent juror unanimity regarding essential factual elements required for imposing a death penalty under state law.

In the dissenting opinion for the case of Bill K. Wilson, Superintendent, Indiana State Prison v. Joseph E. Corcoran in 2010, Justice Stevens argued that the Supreme Court should not have intervened because there was no clear violation of federal law by lower courts and thus no reason to overturn their decisions. He emphasized that it is not within the jurisdiction of a federal court to review state-court judgments on matters such as jury instructions or sentencing procedures unless they clearly infringe upon constitutional rights or contradict established federal laws. In this case, he believed that neither condition had been met; therefore, intervention was unnecessary and inappropriate.