There was a time when the U.S. Court of Appeals for the Ninth Circuit was notorious for issuing decisions at odds with existing Supreme Court precedent, and getting repeatedly overturned as a result. The Ninth Circuit was considered the most liberal circuit in the country at the time, and had a few judges who consciously sought to evade restrictive precedent.

Early in the Roberts Court, the U.S. Court of Appeals for the Sixth Circuit developed something of a reputation as the "new Ninth," particularly with regard to habeas cases. In a string of cases , the Sixth Circuit was reversed, often summarily, for granting habeas petitions too readily.

Both the Ninth and Sixth Circuits are more conservative than they used to be, and are more aligned with the Supreme Court. Today the court that may

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