Cavazos v. Smith
132 S. Ct. 2
| SCOTUS | 2011Background
- Etzel Glass, 7 weeks old, died; mother Tomeka slept in another room while Shirley Ree Smith slept on the floor nearby.
- Autopsy diagnosed SBS; defense claimed SIDS or old trauma as cause of death; prosecution offered three SBS experts.
- Trial evidence spanned seven days of medical testimony; defense offered two experts disputing SBS.
- Jury convicted Smith of assault on a child resulting in death; trial court denied new trial and imposed 15 years to life.
- California Court of Appeal and California Supreme Court denied relief; federal AEDPA standards applied in habeas petition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the evidence sufficient under Jackson v. Virginia? | Smith’s conviction lacked sufficient evidence of SBS as cause of death. | Court of Appeal reasonably credited expert testimony and upheld substantial evidence of SBS. | No; Supreme Court reversed Ninth Circuit, holding evidence sufficient under Jackson. |
| Did the Ninth Circuit misapply AEDPA deference? | State court’s decision was reasonable under AEDPA and Jackson. | Ninth Circuit properly reviewed de novo; discounted trial record. | Yes; Court held Ninth Circuit erred in reweighing and applied proper deference. |
Key Cases Cited
- Jackson v. Virginia, 443 U. S. 307 (U.S. 1979) (sufficiency standard: rational trier of fact can find guilt beyond a reasonable doubt)
- Renico v. Lett, 559 U. S. 766 (U.S. 2010) (objectively unreasonable standard for state court conclusions)
- Harrington v. Richter, 562 U. S. 86 (U.S. 2011) (AEDPA review limitations in federal habeas around state court findings)
- McDaniel v. Brown, 558 U. S. 120 (U.S. 2010) (per curiam AEDPA considerations in fact-intensive cases)
- Carey v. Musladin, 549 U. S. 70 (U.S. 2006) (limits on federal review of state-court evidentiary rulings)