In the case of Richard E. Early, Warden, et al. v. William Packer in 2002, the U.S Supreme Court ruled on a dispute regarding habeas corpus relief for state prisoners under federal law. The respondent, William Packer had been convicted of various crimes and sentenced to prison in California but claimed that his constitutional rights were violated during his trial due to ineffective counsel and prosecutorial misconduct. After exhausting all state court remedies without success, he sought federal habeas corpus relief which was denied by both District Court and Ninth Circuit appeals court initially but granted upon rehearing by the latter citing 'unreasonable application' clause of Antiterrorism & Effective Death Penalty Act (AEDPA). However, this decision was reversed by Supreme Court with a 9-0 vote stating that Ninth Circuit's interpretation of AEDPA standards was incorrect as it failed to recognize difference between an unreasonable and incorrect application of Federal Law thereby expanding scope for granting Habeas Corpus relief beyond what is provided under AEDPA.

In the dissenting opinion for Richard E. Early, Warden, et al. v. William Packer (2002), Justice Scalia disagreed with the majority's decision to reverse and remand the case back to lower courts based on a procedural error in applying federal law instead of state law during habeas corpus proceedings. He argued that this was an unnecessary step since there was no dispute over whether or not Packer had exhausted his state remedies before seeking federal relief as required by statute 28 U.S.C §2254(b)(1). Furthermore, he believed that even if there were such a dispute, it should have been resolved at district court level rather than Supreme Court level because it is essentially factual in nature and therefore outside of Supreme Court jurisdiction according to Rule 10 of Rules of Supreme Court.