for the Mercer Law Review, Stuart E. Walker suggested that the Court's narrow interpretation of standards for federal habeas relief presents a "formidable barrier" to habeas petitioners and, "[g]iven the Supreme Court’s decision in Bell v. Cone'', many state prisoners seeking federal habeas relief for ineffective assistance claims may face a dim future." Wayne M. Helge also wrote that "viewed in light of Strickland's presumption of reasonable professional conduct by counsel," the Supreme Court's ruling will ultimately make "state court holdings practically unchallengeable on the merits." See also List of United States Supreme Court cases Lists of United States Supreme Court cases by volume List of United States Supreme Court cases by the Rehnquist Court References External links 2002 in United States case law United States death penalty case law United States Supreme Court cases United States Supreme Court cases of the Rehnquist Court