In Wilson v. Sellers, 138 S. Ct. 1188 (2018), this Court explicitly stated that a federal court on habeas review must look to the actual reasoning of the last reasoned state court opinion, not what the state court could have reasoned under 28 U.S.C. § 2254(d)(1). The Sixth Circuit, in disregard of Wilson's command, explicitly relied on a new legal theory not included in the relevant state court opinion and affirmed Petitioner Mary Danielak's conviction on that basis. Did the Sixth Circuit err by applying the pre-Wilson "could-have-reasoned" approach—which blatantly disregarded Wilson and created a split with other Circuits—warranting the grant of this petition or, in the alternative, summary reversal?

Did the Sixth Circuit err by applying the pre-Wilson 'could-have-reasoned' approach—which blatantly disregarded Wilson and created a split with other Circuits—warranting the grant of this petition or, in the alternative, summary reversal?