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Habeas Review – Sufficiency of Evidence

Coleman v. Lorenzo Johnson, USSC No. 11-1053, 5/29/12 (per curiam), reversing 446 Fed. Appx. 531 (3rd Cir. 2011)

We have made clear that Jackson claims face a high bar in federal habeas proceedings because they are subject to two layers of judicial deference. First, on direct appeal, “it is the responsibility of the jury—not the court—to decide what conclusions should be drawn from evidence admitted at trial. A reviewing court may set aside the jury’s verdict on the ground of insufficient evidence only if no rational trier of fact could have agreed with the jury.” Cavazos v. Smith, 565 U. S. 1, ___ (2011) (per curiam) (slip op., at 1). And second, on habeas review, “a federal court may not overturn a state court decision rejecting a sufficiency of the evidence challenge simply because the federal court disagrees with the state court. The federal court instead may do so only if the state court decision was ‘objectively unreasonable.’” Ibid. (quoting Renico v. Lett, 559 U. S. ___, ___ (2010) (slip op., at 5)).

Under Jackson, evidence is sufficient to support a conviction if, “after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” 443 U. S., at 319.

This is on review of habeas relief by the Third Circuit, which concluded that the evidence was insufficient to support Johnson’s state murder conviction as an accomplice. The result, of course, is highly fact-specific, and the details won’t be recited here. Read the short (7-page) slip opinion and decide for yourself just how thin the support for Johnson’s guilt. Of more generalized interest is the Court’s criticism of the lower court as having “unduly impinged on the jury’s role as factfinder,” thus violating the deferential-review regime: “This deferential standard does not permit the type of fine-grained factual parsing in which the Court of Appeals engaged.”

On the basis of these facts, a rational jury could infer that Johnson knew that Walker was armed with a shotgun; knew that he intended to kill Williams; and helped usher Williams into the alleyway to meet his fate. The jury in this case was convinced, and the only question under Jackson is whether that finding was so insupportable as to fall below the threshold of bare rationality. The state court of last review did not think so, and that determination in turn is entitled to considerable deference under AEDPA, 28 U. S. C. §2254(d).

File under, “Deference, Deference Thou Shalt Pursue.”

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