The combatants in the battle over campaign finance reform can stand down for another day. On Tuesday the Supreme Court did not issue the long-awaited ruling in Citizens United v. Federal Election Commission, which threatens the future of the ban on direct corporate expenditures in campaigns. The Court is expected to issue opinions again today, so the respite may be brief.

The Court handed down only one decision Tuesday: Smith v. Spisak, a 9-0 defeat for Ohio death row inmate Frank Spisak Jr. The Court, in an opinion (pdf) written by Justice Stephen Breyer, rejected federal habeas claims about improper jury instructions and ineffective assistance of counsel, even though the defense lawyer disparaged his own client.