In the case of Raymond L. Middleton, Warden v. Sally Marie McNeil in 2003, the United States Supreme Court was asked to consider whether a state court's decision could be overturned due to an unreasonable application of federal law. The petitioner, Sally Marie McNeil had been convicted for second-degree murder and sentenced to 15 years-to-life imprisonment by a California jury. She appealed her conviction on grounds that she received ineffective assistance from her counsel during trial because he failed to investigate and present evidence related to battered women’s syndrome (BWS). However, both the California courts and Federal District Court rejected this claim stating that even if BWS evidence were presented it wouldn’t have changed the outcome given other strong evidences against her including eyewitness testimony etc., thus not constituting ineffective counsel under Strickland standard (a legal precedent which sets standards for judging effectiveness of defense attorneys). When brought before Supreme Court they denied certiorari i.e., refused review thereby upholding lower court decisions.

In the dissenting opinion for Raymond L. Middleton, Warden v. Sally Marie McNeil, Justice O'Connor disagreed with the majority's decision to overturn a lower court ruling that had granted habeas corpus relief to McNeil on her murder conviction. She argued that there was sufficient evidence of ineffective counsel during McNeil's trial and thus she should have been given a new one. Specifically, she pointed out that McNeil’s defense attorney failed to investigate or present significant mitigating evidence during the penalty phase of her trial which could have potentially resulted in a lesser sentence than death. This included information about her history as an abused spouse and psychological reports indicating diminished capacity at the time of the crime due to steroid use and alcohol abuse - factors which might have influenced jury members' decisions regarding sentencing if they were presented with such facts.