In the case of Arthur Calderon, Warden v. Thomas Thompson in 1997, the U.S. Supreme Court ruled that a federal court had overstepped its authority by granting habeas corpus relief to death row inmate Thomas Martin Thompson without allowing California courts an opportunity to correct their own errors first. The decision was based on procedural grounds and did not address whether or not Thompson's conviction for rape and murder was valid. The majority opinion held that the Ninth Circuit Court of Appeals had improperly applied "de novo" review instead of deferring to state court findings, violating principles of comity and federalism inherent in habeas corpus law under Title 28 U.S.C Section 2254(d). This ruling emphasized respect for state courts' ability to interpret their own laws correctly.

In the dissenting opinion for Arthur Calderon, Warden v. Thomas Thompson, Justice Stevens argued that the majority's decision to overturn a federal court ruling granting habeas corpus relief was incorrect and unjust. He contended that there were significant procedural errors in Thompson's original trial which had led to his wrongful conviction of murder and death sentence. These included misleading jury instructions and failure by defense counsel to present crucial evidence about another potential suspect during the penalty phase of trial. Furthermore, he criticized the majority for not respecting principles of finality as they overturned two lower courts' decisions without any compelling justification or new evidence presented by California authorities who sought reinstatement of Thompson’s capital sentence. The justice emphasized that such disregard undermines public confidence in judicial proceedings while also causing unnecessary delay in resolution of cases.