The U.S. Supreme Court case Jeanne Woodford, Warden v. John Louis Visciotti in 2002 revolved around the issue of whether or not a state court's decision was unreasonable and therefore violated federal law. The respondent, John Louis Visciotti, had been convicted for first-degree murder and attempted murder in California and sentenced to death penalty. His conviction was upheld by the California Supreme Court but later overturned by the Ninth Circuit on habeas corpus review due to ineffective assistance of counsel during sentencing phase of his trial. However, the U.S Supreme Court reversed this decision stating that under Antiterrorism and Effective Death Penalty Act (AEDPA) standards, it could not be said that state court’s conclusion approving performance of defense counsel was an 'unreasonable application' of clearly established Federal law as determined by US Supreme Court precedent.

In the dissenting opinion for Woodford v. Visciotti, Justice Stevens argued that the majority's decision to overturn a federal court ruling was based on an incorrect interpretation of the Antiterrorism and Effective Death Penalty Act (AEDPA). He contended that AEDPA does not require deference to state court decisions if they are unreasonable applications of clearly established Federal law. In this case, he believed that the California Supreme Court had unreasonably applied Strickland v. Washington by failing to properly assess whether counsel’s deficient performance prejudiced Visciotti during his trial. Furthermore, he criticized the majority for ignoring evidence suggesting racial bias in jury selection and for applying a double standard when reviewing state versus federal courts' findings of fact.