In the case of Arthur Calderon, Warden v. Russell Coleman in 1998, the United States Supreme Court ruled on a habeas corpus petition filed by death row inmate Russell Coleman. The court had to decide whether federal courts could review state court decisions if new evidence was presented that wasn't available during the original trial or appeal process. In this case, Coleman claimed he had newly discovered evidence proving his innocence and argued that his constitutional rights were violated because he couldn't present it in state court due to procedural default rules (rules which limit when a defendant can raise certain issues). However, the Supreme Court held that federal courts cannot review claims defaulted in state court unless there is cause for default and actual prejudice resulting from alleged violation of federal law or unless failure to consider such claims would result in a fundamental miscarriage of justice. Since Coleman did not meet these criteria as determined by lower courts' findings - no showing of "cause" for his procedural default nor demonstration of "actual innocence", hence his claim was dismissed.

In the dissenting opinion for Arthur Calderon, Warden v. Russell Coleman (1998), Justice Stevens argued that the majority's decision to deny habeas corpus relief was based on an overly rigid interpretation of procedural rules at the expense of fundamental fairness. He contended that Coleman had presented a compelling case for actual innocence and should be allowed to present his evidence in federal court despite any procedural default at state level. The justice also criticized the majority's reliance on Teague v. Lane, arguing it was not applicable as it dealt with new constitutional rules rather than factual claims of innocence like this one. Furthermore, he expressed concern over how such strict adherence to procedural bars could potentially lead to miscarriages of justice by preventing genuinely innocent people from proving their innocence in court.