Brown v. O'Brien, 2012 WL 178378

Brown, convicted in Massachusetts for two counts of first-degree murder, was denied federal habeas relief and appeals to the First Circuit.
A shotgun, purchased by Brown's friend Bobbitt with Brown's money, was recovered and linked to the murders; Bobbitt admitted the gun was Brown's.
Brown and accomplices fired the shotgun in Brooklyn/Roxbury area and in the South End, killing Oliveira and Meyer; multiple witnesses could not definitively identify Brown.
Shell casings from the crime scenes matched Brown's shotgun; a green jacket found in Brown's apartment matched the jacket Brown wore the night of the shootings.
Brown underwent multiple competency evaluations at Bridgewater State Hospital; after contested hearings, he was deemed competent to stand trial by state authorities.
At trial, Brown's insanity defense prevailed in defense expert testimony, but Massachusetts lay and expert testimony supported a verdict of insanity; the SJC affirmed the conviction, and Brown pursued federal habeas review under 28 U.S.C. § 2254.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the identification evidence	Brown contends Jackson is violated due to lack of strong identification.	State court properly found sufficient evidence including similarities and firearm linkage.	Evidence sufficient under Jackson; Brown cannot prevail on this challenge.
Applicability of Jackson after defense case added evidence	Jackson should disregard later-provided evidence (defense/rebuttal).	Jackson analysis applies to overall record; later evidence permissible.	Jackson framework not limited to opening case; record supports guilt with full record.
Intoxication instruction	Trial court should have given intoxication instruction based on testimony.	No disabling intoxication evidence; instruction not required.	No due process violation; instruction not warranted given lack of disabling intoxication evidence.
Competence to stand trial	Trial court failed to ensure Brown's competency; procedures defective.	Competence findings were reasonable and reviewable for reasonableness.	State court's competency determination was not unreasonable under deferential habeas review.
Voluntariness of statements	District court should have sua sponte reviewed voluntariness due to mental illness concerns.	Voluntariness and admissibility were properly handled under state law; due process not violated.	No federal due process violation; statements admissible under context and state-law framework.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence standard for reasonable jury)
O'Laughlin v. O'Brien, 568 F.3d 287 (1st Cir. 2009) (rare Jackson challenges; comparative evidence cases)
LaMere v. Slaughter, 458 F.3d 878 (9th Cir. 2006) (Jackson applicability to prosecution's case; standard)
Hernandez v. Cowan, 200 F.3d 995 (7th Cir. 2000) (Jackson analysis across circuits)
McDaniel v. Brown, 130 S. Ct. 665 (2010) (reaffirmed Jackson test after viewing the record as a whole)
Dusky v. United States, 362 U.S. 402 (U.S. 1960) (standard for competence to stand trial)
Commonwealth v. DiPadova, 951 N.E.2d 891 (Mass. 2011) (Mass. insanity standard and McHoul framework)
Williams v. Taylor, 529 U.S. 362 (U.S. 2000) (contrasts between law and fact review in habeas)
Cullen v. Pinholster, 131 S. Ct. 1388 (U.S. 2011) (limitations on evidentiary review in habeas)
In re Winship, 397 U.S. 358 (U.S. 1970) (proof beyond a reasonable doubt standard)