In the case of J.D. Netherland, Warden v. Lem Davis Tuggle in 1994, the U.S Supreme Court was tasked with deciding whether a federal court could review a state prisoner's claim that his death sentence was imposed in violation of the Eighth Amendment because it had been based on materially inaccurate information. The petitioner, Lem Davis Tuggle Jr., convicted for rape and murder in Virginia State Court, claimed that he received ineffective assistance from his counsel during sentencing proceedings as they failed to object to an incorrect statement made by prosecution about him having prior convictions for violent sexual assaults which were actually dismissed charges. The Supreme Court ruled against Tuggle stating that even if there was an error due to false information being presented at trial or inadequate representation by counsel during sentencing phase, it did not have substantial impact on jury’s decision making process given overwhelming evidence of guilt and severity of crime committed by him. Therefore, no relief could be granted under Federal law (28 U.S.C §2254) which allows federal courts to grant habeas corpus only when state court adjudication resulted in decision contrary to clearly established Federal law or involved unreasonable application thereof.

In the dissenting opinion for Netherland, Warden v. Lem Davis Tuggle, Justice Blackmun argued that the majority's decision to deny habeas corpus relief was incorrect due to a failure in considering all relevant factors of the case. He believed that there were significant issues with both the guilt and penalty phases of Tuggle's trial which warranted further review. Specifically, he pointed out problems with eyewitness identification procedures used during investigation and potential juror bias against mental health defenses as key areas where constitutional violations may have occurred. Furthermore, he criticized Virginia courts' handling of post-conviction proceedings and their refusal to consider new evidence supporting Tuggle’s innocence claims or mitigating circumstances related to his mental health status at time of crime commission. In essence, Justice Blackmun felt that these procedural errors undermined confidence in outcome reliability thus violating defendant’s right to fair trial under Due Process Clause.