In the case of Ronald D. Edwards, Warden v. Robert W. Carpenter in 1999, the U.S Supreme Court addressed whether a federal court could grant habeas corpus relief to a state prisoner based on an alleged error that was not objected to during trial and therefore forfeited under state law. The petitioner, Robert Carpenter had been convicted for murder but argued his Sixth Amendment rights were violated when he wasn't allowed to cross-examine a witness about her plea agreement with the prosecution - an issue he failed to raise at trial or on direct appeal in Michigan courts. The Supreme Court held that federal courts may not grant habeas corpus relief due to errors which are defaulted under independent and adequate state procedural rules unless there is cause for default and actual prejudice as a result of violation of federal law or if failure would result in fundamental miscarriage of justice (actual innocence). In this case, it found no such exception applicable hence denied Carpenter's petition.

In the dissenting opinion for Ronald D. Edwards, Warden v. Robert W. Carpenter, Justice Scalia argued that the majority's decision was inconsistent with federal law regarding habeas corpus petitions and would lead to an increase in frivolous claims by prisoners seeking relief from their sentences. He contended that a procedural default should not be excused simply because a prisoner can show cause and prejudice; instead, he believed there must also be evidence of actual innocence or some other extraordinary circumstance justifying such relief. Furthermore, Scalia criticized the majority for creating confusion about what constitutes ineffective assistance of counsel under Strickland v Washington standard and how it applies to cases involving procedural defaults on appeal.