Brookey West v. Sheryl Foster, 454 F. App'x 630

West appeals denial of her 28 U.S.C. § 2254 petition challenging Nevada Supreme Court’s AEDPA ruling on corpus delicti evidence.
District court denied habeas relief and declined to expand the Certificate of Appealability.
Court applies de novo review; AEDPA requires unreasonable application of Supreme Court precedent for warranting relief.
Supreme Court standard for sufficiency of evidence: viewed in light most favorable to the prosecution, any rational trier could find elements beyond a reasonable doubt.
Court notes circumstantial evidence including manner of body discovery, bag over face, West–victim relationship, and fabrication of relocation story to California.
Decision affirms district court’s denial; COA expansion request denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Nevada Supreme Court’s corpus delicti ruling was unreasonable under AEDPA	West: Nev. Sup. Court erred applying Supreme Court law	West contends correct standard not met	No; decision not unreasonable under AEDPA
Whether the evidence suffices under Jackson v. Virginia	Indeterminacy of medical evidence undermines sufficiency	Other circumstantial evidence supports conviction	Evidence sufficient viewing pro prosecution-benefit; rational trier could convict
Whether the COA should be expanded to include additional issues			No; no reasonable jurist would debate district court’s ruling

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence standard: rational trier could find elements beyond reasonable doubt)
Woodford v. Visciotti, 537 U.S. 19 (U.S. 2002) (highly deferential AEDPA review; presume state court rulings correct)
Sims v. Rowland, 414 F.3d 1148 (9th Cir. 2005) (unreasonable application standard under AEDPA)
Dows v. Wood, 211 F.3d 480 (9th Cir. 2000) (AEDPA review standard for state-court decisions)
Johnson v. Louisiana, 406 U.S. 356 (U.S. 1972) (contextual basis for reasonable-doubt standard)