In the case of Margaret Bradshaw, Warden v. Kenneth T. Richey in 2005, the U.S Supreme Court was asked to consider whether a federal court had erred in granting habeas corpus relief to Kenneth Richey, who had been convicted for arson and murder in Ohio state court. The Sixth Circuit Court of Appeals ruled that his conviction was flawed because his lawyers failed to present an alternative theory about how the fire started which could have potentially exonerated him. However, this decision was challenged by Margaret Bradshaw on behalf of the State arguing that it violated established principles regarding deference to state courts' findings under federal law (Antiterrorism and Effective Death Penalty Act). The Supreme Court vacated the judgment and remanded back to lower courts for further consideration without making any substantive ruling on merits or demerits of arguments presented before them.

In the dissenting opinion for the case of Margaret Bradshaw, Warden v. Kenneth T. Richey, 2005, it was argued that the majority's decision to grant habeas corpus relief based on ineffective assistance of counsel during sentencing was incorrect. The dissenting justices believed that there wasn't sufficient evidence to prove that Richey's legal representation had been deficient or prejudicial in any way during his trial and sentencing phase. They also disagreed with the majority’s interpretation of Ohio law regarding arson charges and felt this misinterpretation led them to wrongly conclude that Richey’s rights were violated when he was not allowed a lesser included offense instruction at trial. Furthermore, they held concerns about federal courts overstepping their bounds by intervening in state court decisions without clear justification under established precedent.