In the case of Aaron Lindh v. James P. Murphy, Warden (1996), Lindh was convicted for murder and attempted robbery in Indiana state court and sentenced to 40 years imprisonment without parole eligibility until half his sentence had been served. He filed a federal habeas corpus petition claiming that he was denied effective assistance of counsel because his attorney failed to object when the trial judge instructed the jury on an incorrect legal standard regarding intent, which violated his Sixth Amendment rights. The District Court dismissed this claim as procedurally defaulted since it hadn't been raised during state proceedings. The Seventh Circuit affirmed this decision stating that procedural default could only be excused if there's cause for failure to comply with state procedure and actual prejudice resulted from alleged violation of federal law. However, Supreme Court reversed these decisions arguing that ineffective assistance claims constitute "cause" excusing procedural default if they're first presented in federal habeas proceedings rather than at trial or on direct review; thus remanding case back down for further consideration.

The dissenting opinion in the case of Aaron Lindh v. James P. Murphy, Warden argued that the majority's interpretation of the Anti-Terrorism and Effective Death Penalty Act (AEDPA) was incorrect. The dissent believed that Congress intended for AEDPA to apply to all cases pending on or after its enactment date, not just those filed afterwards as determined by the majority. They pointed out that this interpretation would lead to unequal treatment of habeas corpus petitioners depending solely on when they filed their petitions relative to AEDPA’s effective date - a result they deemed arbitrary and unfair. Furthermore, they contended that there were no clear indications from Congress suggesting such an intention; instead, it seemed more likely based on legislative history and statutory language that Congress meant for AEDPA provisions to apply immediately upon enactment without exception.