Supreme Court Decides Coleman v. Johnson
On May 29, 2012, the U.S. Supreme Court decided Coleman v. Johnson (No. 11-1053) in a per curiam opinion, reversing the Third Circuit's grant of habeas relief and holding that a federal court may grant habeas relief based on insufficient evidence supporting the conviction only if the state court decision is objectively unreasonable. The Court applied the standard for habeas review in the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U.S.C. § 2254, as set forth in Jackson v. Virginia, 443 U.S. 307 (1979).
Respondent Lorenzo Johnson was convicted in Pennsylvania as an accomplice and co-conspirator in the murder of Taraja Williams. The evidence at trial demonstrated that Johnson and Corey Walker had attempted to collect a debt from Williams. During this encounter, Williams had beaten Walker with a broom, embarrassing him in front of a crowd of people. Afterward, Walker repeatedly said that he was going to "kill" Williams. The evening after the encounter, multiple witnesses saw Walker and Johnson walking Williams in a single-file line into an alley while Walker concealed something under his long coat. Afterward, witnesses heard a "loud boom," and Williams's body was found in the alley, dead from a shotgun wound.
The Pennsylvania Supreme Court affirmed Johnson's conviction on direct appeal, and Johnson unsuccessfully sought state post-conviction relief. Then he filed a habeas petition in the federal district court, which was denied. On appeal, the Third Circuit reversed the district court and granted habeas relief, holding that the evidence at trial was insufficient to support Johnson's conviction under the standard in Jackson v. Virginia.
Granting certiorari, the U.S. Supreme Court summarily reversed the Third Circuit, holding that the state court's conviction was entitled to more deference under AEDPA. The Court noted that the only question under Jackson's due process analysis is "whether that finding was so insupportable as to fall below the threshold of bare rationality." The Court found that the Third Circuit erred in concluding that no rational fact finder could have determined that Johnson shared Walker's intent to kill Williams based upon the evidence presented. Under the deferential federal standard afforded under Jackson, the Court noted that juries have "broad discretion in deciding what inferences to draw from the evidence presented at trial, requiring only that jurors draw reasonable inferences from basic facts to ultimate facts." In this instance, the Court found that Johnson's intent could be inferred from the evidence presented that Johnson helped escort Williams into an alley, where Johnson stood in the entryway while Walker pulled out a shotgun and shot Williams in the chest.
The Court's opinion was per curiam.