In the case of Randy White, Warden v. Roger L. Wheeler, 2015, the U.S Supreme Court was asked to review a decision by the Sixth Circuit which granted habeas relief to Wheeler on his murder conviction in Kentucky state court. The issue at hand was whether or not Wheeler's right to confront witnesses against him had been violated when a lab report used as evidence wasn't supported with live testimony from its authoring analyst. The Supreme Court reversed and remanded the Sixth Circuit’s judgment based on two precedents: Bullcoming v New Mexico (2011) and Melendez-Diaz v Massachusetts (2009). These cases established that defendants have a constitutional right under the Confrontation Clause of the Sixth Amendment to cross-examine forensic analysts who prepare reports for use in criminal trials unless they are unavailable and there has been an opportunity for prior cross-examination.

The dissenting opinion in the case of Randy White, Warden v. Roger L. Wheeler argued that the majority's decision to grant habeas corpus relief was incorrect because it failed to properly apply the Antiterrorism and Effective Death Penalty Act (AEDPA). The dissenters believed that AEDPA required deference to state court decisions unless they were contrary to or an unreasonable application of clearly established federal law as determined by Supreme Court precedent. They contended that there was no such precedent applicable in this case, thus making it inappropriate for a federal court to overturn a state court’s decision on constitutional grounds without clear guidance from Supreme Court jurisprudence. Furthermore, they disagreed with the majority's interpretation of Strickland v. Washington standard for ineffective assistance of counsel claims, arguing that Wheeler had not demonstrated his counsel’s performance fell below an objective standard of reasonableness nor shown prejudice resulting from alleged deficient performance.