In the case of Jeffrey Woods, Warden v. Timothy Etherton in 2015, the US Supreme Court ruled in favor of petitioner Jeffrey Woods. The respondent, Timothy Etherton was convicted for shooting a man during an altercation and his conviction was upheld by Michigan state courts despite claims that his counsel had been ineffective. On federal habeas review, however, the Sixth Circuit found that he received ineffective assistance of counsel because his lawyer failed to request a self-defense instruction at trial and granted him relief from his sentence. The Supreme Court reversed this decision stating that it violated established legal principles under Federal law which requires deference to State court decisions unless they are contrary to or involve unreasonable application of clearly established Federal Law as determined by the Supreme Court itself.

In the dissenting opinion for the case of Jeffrey Woods, Warden v. Timothy Etherton, Justice Sonia Sotomayor disagreed with the majority's decision to overturn a lower court ruling that had granted habeas relief to Etherton. She argued that the Sixth Circuit correctly applied federal law in granting relief based on ineffective assistance of counsel during his trial and appeal process. According to her, Etherton’s attorney failed him by not challenging key evidence presented against him at trial - an error which was then compounded when his appellate lawyer did not raise this issue on appeal. This failure resulted in prejudice towards Etherton as it significantly undermined confidence in his conviction outcome. Therefore, she believed that these cumulative errors warranted a new trial for Mr.Etherton.