The U.S. Supreme Court case Brian Coleman, Superintendent, State Correctional Institution at Fayette, et al. v. Lorenzo Johnson in 2011 revolved around the issue of habeas corpus relief and whether a federal court can grant it based on its own interpretation of state law that contradicts the state court's findings. Lorenzo Johnson was convicted for first-degree murder and conspiracy to commit murder in Pennsylvania but appealed his conviction claiming insufficient evidence. The District Court denied his appeal but the Third Circuit reversed this decision stating that no reasonable juror could have found him guilty beyond a reasonable doubt based on available evidence - effectively granting him habeas corpus relief from imprisonment. However, upon review by the Supreme Court, it was determined that under existing laws (Antiterrorism and Effective Death Penalty Act), federal courts cannot overturn state court decisions unless they are contrary to or involve an unreasonable application of clearly established Federal law as determined by the Supreme Court itself or if they are based on an unreasonable determination of facts considering presented evidence. As such, since there were no grounds suggesting either scenario with respect to Johnson’s case according to majority opinion led by Justice Scalia; hence his petition was dismissed thereby reinstating original verdict.

In the dissenting opinion for Coleman v. Johnson, Justice Scalia, joined by Justices Thomas and Alito, argued that the majority had overstepped its bounds in overturning a state court decision based on federal habeas corpus law. The dissenters believed that under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), federal courts should defer to state court decisions unless they were unreasonable applications of clearly established Federal law or based on an unreasonable determination of facts. They contended that the Pennsylvania Supreme Court's decision was not unreasonable because it relied on circumstantial evidence which could lead a rational trier of fact to find guilt beyond reasonable doubt. Therefore, according to them, there was no basis for granting habeas relief as per AEDPA standards.