The U.S. Supreme Court case Flora Holland, Warden v. Jessie L. Jackson in 2003 revolved around the issue of whether a prisoner's habeas corpus petition should be considered "second or successive" under the Antiterrorism and Effective Death Penalty Act (AEDPA) if it raises claims that could have been but were not presented in an earlier petition. The petitioner, Jessie L. Jackson, was convicted for murder and sentenced to death by an Alabama court in 1982; he filed several unsuccessful state and federal petitions challenging his conviction and sentence over the years. In this particular case, after losing his appeal before the Eleventh Circuit Court of Appeals on procedural grounds related to AEDPA's restrictions on second or successive petitions, Jackson sought review from the Supreme Court arguing that these restrictions did not apply because he had new evidence supporting his claim of innocence. However, without providing any written opinion explaining its decision-making process or reasoning behind its judgment - which is quite common when denying certiorari - ,the Supreme Court declined to hear Jackson’s appeal thereby leaving intact lower courts' rulings against him.

The dissenting opinion in the case of Flora Holland, Warden v. Jessie L. Jackson argued that the majority's decision to deny habeas corpus relief was incorrect because it failed to consider whether or not Jackson had received effective legal counsel during his trial and sentencing. The dissent believed that there were clear indications of ineffective assistance from Jackson’s lawyer, who did not present crucial mitigating evidence about his client's mental health issues and troubled upbringing during the penalty phase of his trial for murder. This information could have potentially swayed jurors towards a sentence less severe than death. Furthermore, they disagreed with the majority's interpretation of federal law regarding when a state prisoner can seek federal review of their claims; they felt this interpretation was too restrictive and limited prisoners' access to justice.