In the case of Woods v. Donald, 2014, Quintez Woods was convicted in Michigan state court for second-degree murder and other charges related to a shooting. His appointed counsel failed to be present during the testimony of a police officer who had interrogated him after his arrest. The attorney's absence violated Wood’s Sixth Amendment right to counsel; however, the Michigan Court of Appeals ruled that this did not warrant automatic reversal because it didn't affect the outcome of his trial as per United States v Cronic (1984). This decision was upheld by both federal district court and U.S Court of Appeals for Sixth Circuit. The Supreme Court unanimously reversed these decisions stating that under precedent set by Cronic, an attorney's complete denial at a critical stage in trial requires automatic reversal without showing prejudice against defendant’s interest. However, they clarified that not all stages where lawyer is absent are 'critical'. In this case though, since evidence from missing portion could have been used in defense strategy or cross-examination later on - it constituted as 'critical' stage thus requiring new trial.

In the dissenting opinion for Woods v. Donald, Justice Scalia, joined by Justices Thomas and Alito, argued that the majority had overstepped its authority in granting habeas relief to a state prisoner based on Michigan Court of Appeals' decision. The dissenters contended that under the Antiterrorism and Effective Death Penalty Act (AEDPA), federal courts should defer to state court decisions unless they were contrary to or involved an unreasonable application of clearly established Federal law as determined by Supreme Court precedent. They asserted that there was no such clear precedent at issue here; thus, it was inappropriate for the majority to grant relief based on their own interpretation of what constitutes ineffective assistance of counsel under Strickland v. Washington standard without any specific guidance from prior Supreme Court cases addressing similar factual circumstances.