In the case of Deborah K. Johnson, Warden v. Donna Kay Lee in 2015, the Supreme Court was asked to consider whether a California state court's decision that Lee had not received ineffective assistance of counsel during her trial was contrary to or an unreasonable application of federal law as determined by the U.S Supreme Court. The Ninth Circuit had previously granted habeas relief on this issue but it was reversed by the Supreme Court without comment and remanded for further proceedings consistent with its opinion in Harrington v Richter (2011). In that case, it held that even if defense counsel's performance is deficient under Strickland v Washington (1984), there must be a reasonable probability that outcome would have been different absent those errors for defendant to prevail on claim of ineffective assistance.

In the dissenting opinion for Deborah K. Johnson, Warden v. Donna Kay Lee, it was argued that the majority's decision to reverse the Ninth Circuit Court of Appeals' ruling failed to respect precedent and misinterpreted federal law regarding habeas corpus petitions. The dissent contended that under 28 U.S.C §2254(d)(2), a state court decision can be considered unreasonable if it is based on an unreasonable determination of facts in light of evidence presented during trial or post-trial proceedings. They believed that this standard had been met in Lee’s case due to significant inconsistencies and contradictions within her confession which were not adequately addressed by the state court. Therefore, they felt she should have been granted relief from her conviction as per her petition for writ of habeas corpus.