In the case of T. Felkner v. Steven Frank Jackson, 2010, the U.S Supreme Court overturned a decision by the Ninth Circuit Court of Appeals that had granted habeas corpus relief to Steven Frank Jackson on his claim that racial bias influenced jury selection in his trial. The Supreme Court ruled per curiam (by the court as a whole), stating that there was no clear evidence supporting Jackson's claims and criticized the Ninth Circuit for its "dismissive and strained interpretation" of state-court rulings. This ruling reinforced previous decisions emphasizing deference to state courts' factual findings unless they are unreasonable based on clear evidence.

The dissenting opinion in the case of T. Felkner v. Steven Frank Jackson disagreed with the majority's decision to overturn a lower court ruling that had upheld a jury verdict in favor of Jackson, an African American man convicted of murder and attempted murder by an all-white jury. The dissent argued that there was sufficient evidence to suggest racial bias may have influenced the prosecutor's use of peremptory challenges during jury selection, which resulted in no black jurors being selected for trial. They pointed out that this could potentially violate Batson v Kentucky (1986), where it was ruled unconstitutional for prosecutors to exclude potential jurors based on their race. The dissent also criticized the majority for not giving due deference to state courts' factual findings regarding whether or not racial discrimination occurred during jury selection.