In the case of California v. Superior Court of California, San Bernardino County (Smolin et al., Real Parties in Interest), 1986, the U.S Supreme Court ruled that a state court cannot exercise jurisdiction over an out-of-state defendant based solely on the fact that a product manufactured by them caused harm within the state. The case involved Smolins who were injured in California when their car's tire blew out and they sued Goodyear Tire & Rubber Co., which was incorporated and headquartered outside of California. The State Supreme Court held that it had specific jurisdiction because Goodyear did substantial business in California through its subsidiaries but not general jurisdiction as Goodyear wasn't "at home" there. However, this decision was reversed by US Supreme Court stating that such broad interpretation would stretch beyond permissible limits under due process clause and hence no personal jurisdiction could be exercised.

In the dissenting opinion for California v. Superior Court of California, San Bernardino County (Smolin et al., Real Parties in Interest), Justice Brennan, joined by Justices Marshall and Blackmun, argued that the majority's decision to deny a writ of habeas corpus was incorrect because it failed to consider whether or not there had been an "unreasonable application" of clearly established Federal law. The dissenters believed that the state court's decision did involve an unreasonable application of federal law as determined by the Supreme Court. They also disagreed with the majority’s interpretation regarding “clearly established Federal law,” arguing that it should include decisions from lower federal courts as well as Supreme Court precedent. Furthermore, they contended that even if only Supreme Court precedent were considered relevant under this phrase, Smolin’s claim still would have merit based on previous rulings made by them.