In the case of Arthur Calderon, Warden v. Charles Edward Moore Jr., 1995, the U.S Supreme Court ruled in favor of Calderon (the warden). The court held that federal courts should give deference to state court findings on factual issues unless there is clear and convincing evidence to suggest otherwise. This decision was based on a habeas corpus petition filed by Moore who had been convicted for first-degree murder and sentenced to death in California. He claimed his constitutional rights were violated because he wasn't allowed to present mitigating evidence during the penalty phase of his trial due to ineffective assistance from counsel. However, both state and federal courts found no merit in this claim as they determined that Moore's defense team made a strategic choice not to introduce such evidence after careful consideration.

In the dissenting opinion for Arthur Calderon, Warden v. Charles Edward Moore Jr., Justice Stevens argued that the majority's decision to deny habeas corpus relief was incorrect due to its failure to properly consider key elements of Moore's defense. He contended that there were significant mitigating circumstances in this case, including evidence of Moore’s mental illness and his history as a victim of child abuse. These factors should have been considered by the jury during sentencing but were not adequately presented or explained by his counsel at trial. Furthermore, he disagreed with the majority’s view on procedural default rules which they used to bar federal courts from hearing claims defaulted in state court unless cause and prejudice are shown. In Stevens' view, these rules should not be applied mechanically but rather flexibly depending upon each individual case context.