October 31, 2011

Supreme Court Decides Cavazos v. Smith

On October 31, 2011, the U.S. Supreme Court decided Cavazos v. Smith, No. 10-1115, holding in a federal habeas corpus action that a reviewing court may set aside a jury's verdict on the ground of insufficient evidence only if no rational trier of fact could have agreed with the jury, and a federal court may overturn a state court decision rejecting a suf­ficiency of the evidence challenge only if the state court decision was "objectively unreasonable."  

Defendant Smith was convicted in a California state court of assault on a child resulting in death in a jury trial that featured conflicting expert testimony on the cause of the child's death. The defendant appealed based on insufficiency of the evidence, the California Court of Appeals affirmed, and the California Supreme Court denied review. The defendant petitioned for a writ of habeas corpus in federal court. A federal magistrate judge, although noting that that the evidence against the defendant "raises many questions," concluded that the evidence was sufficient to support the conviction and denied the defendant's petition. The United States Court of Appeals for the Ninth Circuit reversed and remanded with instruction to grant the writ, holding that the evidence was not sufficient to permit an expert finding on the cause of death.

The Supreme Court reversed and remanded in a per curiam decision. The Court held that its precedent, most prominently Jackson v. Virginia, 443 U. S. 307 (1979), makes clear that the jury, not the court, has the responsibility to decide what conclusions should be drawn from the evidence, and that 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. A federal court may not overturn a state court's conclusion on suf­ficiency of the evidence merely because it disagrees with the decision, but only if the state court decision is "objectively unreasonable." Because the Ninth Circuit's decision failed to apply this standard, the Court reversed. 

The decision of the Court was issued per curiam. Justice Ginsburg filed a dissenting opinion, in which Justices Breyer and Sotomayor joined. 

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