The U.S. Supreme Court case Lem Davis Tuggle, Jr. v. J.D Netherland, Warden in 1995 revolved around the issue of whether a habeas corpus petitioner was entitled to an evidentiary hearing on his claim that he received ineffective assistance of counsel during sentencing for a capital offense. The court held that Tuggle had not established cause for his procedural default and thus could not proceed with his federal habeas petition based on alleged ineffectiveness of counsel at sentencing phase. Tuggle's attorneys failed to present mitigating evidence about his background during the penalty phase of trial which might have influenced jury's decision regarding death sentence imposition. However, the court found no reasonable probability that outcome would have been different if such evidence were presented because it was largely cumulative or irrelevant given nature and circumstances surrounding crime committed by Tuggle - rape and murder. In conclusion, this case reaffirmed principle that defendants must show both deficient performance by their attorney leading to prejudice as well as overcome any procedural barriers before they can successfully challenge their conviction or sentence based on ineffective assistance claims under Sixth Amendment.

In the dissenting opinion for Tuggle v. Netherland, Justice Stevens argued that the majority's decision to deny habeas corpus relief was based on a misinterpretation of precedent and an overly narrow view of what constitutes "clearly established Federal law." He contended that the Virginia Supreme Court had unreasonably applied relevant federal laws in its ruling. Specifically, he pointed out that it failed to consider mitigating evidence outside of statutory factors during sentencing - a violation of Lockett v. Ohio (1978) and Eddings v. Oklahoma (1982). Furthermore, he criticized the majority for not considering whether this error had substantial or injurious effect on jury's sentence as required by Brecht v. Abrahamson (1993). In his view, there was reasonable probability that consideration of non-statutory mitigating factors could have resulted in different outcome given significant evidence about Tuggle’s mental health issues and troubled background presented at trial.