Jackson v. Virginia

Supreme Court of the United States · 1979 · Federal Courts

Federal CourtsHabeas CorpusDue ProcessSufficiency of the Evidence28 U.S.C. § 2254federal habeas corpusdue processIn re Winship

Facts

Petitioner admitted that he shot and killed Mary Cole, but claimed the shooting was accidental or done in self-defense, and alternatively argued that he was too intoxicated to form the specific intent required for first-degree murder under Virginia law. The evidence showed that he fired several shots into the ground, reloaded his revolver, and then shot the victim twice at close range with a gun he knew how to use. After the shooting he drove the victim's car from Virginia to North Carolina without mishap, and the victim's body was found partially unclothed in a secluded lot. The trial judge, sitting as factfinder, found beyond a reasonable doubt that petitioner committed premeditated first-degree murder.

Issue

In a federal habeas corpus proceeding challenging a state conviction as unsupported by the evidence, is the constitutional standard merely whether there was any evidence supporting the conviction, or whether, viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found guilt beyond a reasonable doubt? Applying that standard here, was the evidence sufficient to sustain petitioner's first-degree murder conviction?

Rule

Under the Due Process Clause as explained in In re Winship, a state conviction cannot constitutionally stand unless it is supported by sufficient evidence to permit a rational trier of fact to find every essential element of the crime beyond a reasonable doubt. In a federal habeas proceeding under 28 U.S.C. § 2254, the reviewing court must ask whether, after viewing all of the trial evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements beyond a reasonable doubt. When the record supports conflicting inferences, the habeas court must presume that the trier of fact resolved those conflicts in favor of the prosecution and must defer to that resolution.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, Diego Marin was convicted in Arizona state court of burglary. After exhausting his state remedies, he files a federal habeas petition arguing that the trial evidence on entry was too weak to support the conviction. The district judge notes there was at least one incriminating witness and considers denying relief on that basis alone.

What standard should the federal habeas court apply to Diego’s sufficiency claim?

Explanation. The governing rule is that a state conviction challenged on federal habeas for insufficient evidence violates due process if, after viewing the trial evidence in the light most favorable to the prosecution, no rational trier of fact could have found the essential elements beyond a reasonable doubt. The Court rejected a mere 'no evidence' or 'any evidence' test as inadequate under Winship.