the due process claims were procedurally barred by the Tennessee state courts in prior proceedings. The Sixth Circuit noted that even if the police reports and witness statements were admitted, they would not outweigh "overwhelming evidence of Cone’s guilt in committing a brutal double murder and the persuasive testimony that Cone was not under the influence of drugs." The United States Supreme Court granted certiorari and vacated the Sixth Circuit's 2007 ruling. In an opinion written by Justice John Paul Stevens in Cone v. Bell (2009), the Supreme Court held that Cone's due process claims should not have been procedurally barred, and the Supreme Court remanded the case to the United States District Court that first examined Cone's habeas petition, "with instructions to give full consideration to the merits of Cone’s [due process] claim." Justice Stevens noted that "the quantity and the quality of the suppressed evidence lends support to Cone’s position at trial that he habitually used excessive amounts of drugs, that his addiction affected his behavior during his crime spree, and that the State’s arguments to the contrary were false and misleading." On April 19, 2016, Gary Cone died of natural causes while still sitting on Tennessee's death row. Analysis and commentary Justin Rand noted that Bell v. Cone is significant because it clarified that prejudice will only be presumed in the three circumstances outlined in United States v. Cronic and that all other cases will be analyzed under Strickland v. Washington's standards for evaluating prejudice. However, Jennifer Williams suggested that the Court's ruling intended to limit presumptions of prejudice to cases in which there is a "complete" failure to challenge the prosecution. David A. Moran wrote that the Court's ruling in Bell reaffirmed that "the Cronic rule should apply to absences of counsel from critical stages of a criminal trial." Robert J. Nolan suggested that an "appropriate" interpretation of the Court's ruling would allow judges to presume prejudice for "unauthorized concessions" made during opening arguments because Supreme Court precedent requires that defense counsel "engage in meaningful adversarial testing." In his review of the case for the Suffolk University Law Review, Marc L. Gouthro, wrote that the Supreme Court "correctly" and "accurately" applied existing law to the facts of the case; he also suggested that the Court's ruling "provided concrete guidance for the lower courts to follow when making future decisions." However, in his analysis of the case