The U.S. Supreme Court case Bertram Rice, Warden, et al. v. Steven Martell Collins in 2005 revolved around the issue of habeas corpus relief and whether it was applicable to a defendant who had been convicted based on eyewitness testimony that was later found to be potentially unreliable due to hypnosis-induced memory recall techniques used by law enforcement during their investigation. The petitioner, Bertram Rice (the warden), argued against granting habeas corpus relief for the respondent, Steven Martell Collins (the inmate). The court ruled in favor of Rice stating that even if there were errors made at trial regarding the admissibility of hypnotically refreshed testimony or ineffective assistance from counsel related thereto; these did not have such a substantial and injurious effect or influence as would warrant federal habeas relief under Brecht v. Abrahamson's standard.

In the dissenting opinion for Bertram Rice, Warden, et al. v. Steven Martell Collins (2005), Justice Scalia argued that the majority's decision to grant habeas corpus relief was incorrect because it relied on a misinterpretation of federal law and precedent. He contended that the Antiterrorism and Effective Death Penalty Act (AEDPA) only allows for such relief if a state court's decision is contrary to clearly established Federal law as determined by the Supreme Court itself - not lower courts or other authorities. In this case, he believed there was no Supreme Court ruling directly applicable to Collins' claim about his right to confront witnesses against him being violated due to hearsay evidence admitted at trial without an opportunity for cross-examination. Therefore, Scalia asserted that granting habeas corpus in this situation effectively expanded AEDPA’s scope beyond its intended limits set by Congress.