Last week, I linked to a discussion among three Ninth Circuit judges in which one judge compared reversal by the Supreme Court to being "struck by lightning" and another claimed that the Ninth Circuit's high reversal rate was "largely a media myth." In light of that, I hope the media won't notice that lightning struck yet again today, this time in a 9-0 reversal of the Ninth Circuit in Boulware v. United States. Actually, I would guess the media won't notice this one: The Supreme Court ruled in favor of the criminal defendant, overruling Ninth Circuit caselaw going back to 1976 that had blocked the defendant from putting on a proper defense. (Indeed, the Ninth Circuit panel below can't be faulted for this — they were just following the 1976 precedent.)