The U.S. Supreme Court case Nevada, et al., v. Calvin O’Neil Jackson (2012) revolved around the issue of whether a state can be sued in another state's courts without its consent. The petitioner, the State of Nevada, was sued by respondent Calvin O'Neil Jackson in California for damages related to an accident involving a University of Nevada vehicle driven by one of its employees on a work-related task in California. The State argued that it had sovereign immunity under the Eleventh Amendment and could not be subjected to suit outside its own jurisdiction without consent or waiver thereof. However, both lower court and appellate court ruled against Nevada’s claim asserting that states have no constitutional right to assert their sovereignty in other states' courts. This led to an appeal at the Supreme Court level where justices were divided 4-4 due to Justice Clarence Thomas recusing himself from deliberations as his son attended school at UNLV during this time period. As such, with equal votes on both sides but no majority decision reached among eight participating justices - which is necessary for setting precedent - they upheld lower court rulings allowing Mr.Jackson's lawsuit against Nevada proceed within Californian jurisdiction.

In the dissenting opinion for Nevada v. Jackson, it was argued that the Ninth Circuit Court of Appeals had overstepped its authority by imposing a constitutional rule that states must provide an opportunity to litigate ineffective assistance of trial counsel claims in initial-review collateral proceedings. The dissenters believed this ruling contradicted previous Supreme Court decisions which held that there is no such constitutional right unless state law otherwise provides one. They also disagreed with the majority's interpretation of Martinez v. Ryan, arguing it did not establish a sweeping new constitutional rule but rather addressed a narrow procedural issue specific to Arizona law and should not be applied broadly to all states.