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SCOTUS summary reversal of Ninth Circuit sufficiency ruling

By Douglas A. Berman

The Supreme Court this morning kicked off its new year with a rather lengthy per curiam summary reversal in McDaniel v. Brown, No. 08-559 (Jan. 11, 2010) (available here). The ruling starts this way: In Jackson v. Virginia, 443 U. S. 307 (1979), we heldthat a state prisoner is entitled to habeas corpus relief if afederal judge finds that ?upon the record evidence adducedat the trial no rational trier of fact could have found proofof guilt beyond a reasonable doubt.?  Id., at 324.  A Nevada jury convicted respondent of rape; the evidence presented included DNA evidence matching respondent?s DNA pro-file. Nevertheless, relying upon a report prepared by aDNA expert over 11 years after the trial, the Federal District Court applied the Jackson standard and grantedthe writ...continue to full post

Full post as published by Sentencing Law and Policy on January 11, 2010 (boomark / email).