In Williams v. Taylor (529 U.S. 362, 380-381, 120 S Ct 1495, 146 L Ed 2d 389 [2000]), the Court recognized the "inevitable difficulties" that come with "attempting 'to determine whether a particular decision has really announced a "new" rule at all or whether it has simply applied a well-established constitutional principle to govern a case which is closely analogous to those which have been previously considered in the prior case law.'" However, the Williams Court held that merely applying Strickland to a new scenario does not create a new rule, as "it can hardly be said that recognizing the right to effective counsel breaks new ground or imposes a new obligation on the States" (529 US at 391). The rationale behind this aspect of the holding in Williams is illustrated by Justice Kennedy's explanation that: "If the rule in question is one which of necessity requires a case-by-case examination of the evidence, then we can tolerate a number of specific applications without saying that those applications themselves create a new rule... . Where the beginning point is a rule of this general application, a rule designed for the specific purpose of evaluating a myriad of factual contexts, it will be the infrequent case that yields a result so novel that it forges a new rule, one not dictated by precedent" (Wright v. West, 505 US 277, 308-309, 112 S Ct 2482, 120 L Ed 2d 225 [1992 concurring op]).