In the case of Sexton v. Beaudreaux, 2017, the U.S. Supreme Court reversed a decision by the Ninth Circuit Court of Appeals granting habeas relief to Michael Beaudreaux, who was convicted for murder in California state court. The Ninth Circuit had ruled that Beaudreaux's counsel provided ineffective assistance during his trial because he did not move to suppress evidence from an unconstitutional search and seizure conducted by police officers at his home without a warrant or consent. However, the Supreme Court held that this ruling was erroneous as it failed to apply federal law as determined by its precedents which require deference to state court decisions under Antiterrorism and Effective Death Penalty Act (AEDPA). The high court emphasized that there was no established federal law stating that failure to file a motion equals ineffective assistance of counsel if such motion would have been futile based on existing legal doctrines at time of trial.

In the dissenting opinion for Sexton v. Beaudreaux, it was argued that the majority's decision to overturn a lower court ruling granting habeas relief to Michael Beaudreaux was incorrect. The dissent noted that there were significant issues with how evidence had been handled in his original trial, including potential prosecutorial misconduct and ineffective assistance of counsel. It also pointed out that the majority did not give proper deference to state courts' findings on these matters as required by federal law under AEDPA (the Antiterrorism and Effective Death Penalty Act). Furthermore, they disagreed with the majority's interpretation of Strickland v. Washington - a key precedent case concerning ineffective assistance of counsel claims - arguing instead that this case should have led them to uphold rather than reverse Beaudreaux’s habeas relief.