In the case of Javier Cavazos, Acting Warden v. Shirley Ree Smith in 2011, the U.S Supreme Court overturned a decision by the Ninth Circuit Court of Appeals which had granted habeas corpus relief to Smith. She was convicted in California state court for assaulting her grandson resulting in his death - a crime she denied committing. The Ninth Circuit found that there was insufficient evidence to support her conviction and ruled it as 'a miscarriage of justice'. However, this ruling was reversed by the Supreme Court on grounds that federal courts should not overstep their boundaries when reviewing state court decisions under Antiterrorism and Effective Death Penalty Act (AEDPA). The high court held that even if legal errors were made at trial or appeal level within state courts, they do not necessarily mean an individual's imprisonment violates Constitution; hence federal habeas corpus relief is unwarranted unless it can be shown that no reasonable juror would have voted to convict based on presented evidence.

In the dissenting opinion for Javier Cavazos, Acting Warden v. Shirley Ree Smith, Justice Ruth Bader Ginsburg argued that the Ninth Circuit Court of Appeals was correct in its decision to grant habeas relief to Smith. She believed that no reasonable juror could have found beyond a reasonable doubt that Smith intentionally caused her grandson's death based on the evidence presented at trial. The prosecution’s case relied heavily on now-discredited medical testimony about "shaken baby syndrome," and there were other plausible explanations for the child's death which were not adequately considered by jurors due to this misleading information. Ginsburg also criticized her colleagues' assertion that federal courts should defer more often to state court decisions in habeas cases, arguing instead for rigorous review when constitutional rights are at stake.