In the case of Ashbel T. Wall, II, Director, Rhode Island Department of Corrections v. Khalil Kholi in 2010, the U.S Supreme Court was tasked with determining whether a state court sentence reduction constitutes an application for habeas corpus relief under federal law. The petitioner argued that it does not and therefore should not delay the one-year statute of limitations period for filing a federal habeas petition as stipulated by Antiterrorism and Effective Death Penalty Act (AEDPA). However, respondent Kholi contended that his motion to reduce his sentence did qualify as such an application because it challenged the legality of his custody just like any other habeas corpus proceeding would do so. In unanimous decision led by Justice Alito, the Supreme Court sided with Kholi's interpretation ruling that motions seeking modification or reduction are included within AEDPA’s tolling provision since they challenge “the lawfulness of [a] State’s custody” over a prisoner.

In the dissenting opinion for Ashbel T. Wall, II, Director, Rhode Island Department of Corrections v. Khalil Kholi (2010), Justice Alito argued that the majority's interpretation of "collateral review" was too broad and inconsistent with Congress' intent when drafting the Antiterrorism and Effective Death Penalty Act (AEDPA). He contended that a motion to reduce sentence under Rhode Island law should not be considered collateral review because it does not challenge the legality or constitutionality of a conviction or sentence but merely asks for leniency. Therefore, such motions should not toll AEDPA’s one-year statute of limitations period for filing federal habeas corpus petitions. By including these types of motions in their definition, he believed that the majority had unnecessarily complicated matters by creating ambiguity around what constitutes collateral review and potentially opening up floodgates to numerous other post-conviction applications being included as well.