In the case of Deborah K. Johnson, Acting Warden v. Tara Sheneva Williams in 2012, the U.S Supreme Court was asked to consider whether a state court's decision could be considered "unreasonable" under federal law if it rejects a defendant's claim without providing any reasoning whatsoever. The petitioner argued that such lack of explanation should automatically qualify as unreasonable and thus allow for federal habeas relief - an order requiring that a prisoner be brought before a judge to determine if their detention is lawful. However, the Supreme Court disagreed with this argument and ruled unanimously against Williams. Justice Clarence Thomas wrote for the court stating that even when there is no opinion explaining State court’s rationale on rejecting defendant’s claims, Federal Habeas courts must presume they knew and followed law unless rebutted by applicant by clear evidence.

In the dissenting opinion for Deborah K. Johnson, Acting Warden v. Tara Sheneva Williams, Justice Scalia disagreed with the majority's decision to overturn a lower court ruling that had denied habeas corpus relief to Williams on her claim of ineffective assistance of counsel during sentencing in a murder case. He argued that under federal law, state court decisions can only be overturned if they are contrary to or involve an unreasonable application of clearly established Federal law as determined by the Supreme Court. In his view, this standard was not met because there was no clear precedent from previous Supreme Court cases indicating that defense attorneys must always present mitigating evidence at capital sentencing hearings even when it could potentially open up damaging lines of cross-examination against their clients.