Justice Antonin Scalia wielded a wicked pen that could turn a colorful phrase with sharp edges. Justice Elena Kagan has a colorful pen that turns a wicked phrase with humorous edges that can pull a reader through even a “small and legally mundane” habeas case.

The “small and legally mundane” case was Thursday’s 6-3 ruling in Brown v. Davenport. In the opinion by Justice Neil Gorsuch, the court held that when a state court has ruled on the merits of a prisoner’s claim, a federal court cannot grant habeas relief without applying two tests, one that the justices announced in Brecht v. Abrahamson and the second that Congress included in the Antiterrorism and Effective Death Penalty Act (AEDPA).