Coleman v. Johnson
132 S. Ct. 2060
| SCOTUS | 2012Background
- Johnson was convicted as an accomplice and co-conspirator in the murder of Taraja Williams by Corey Walker, who shot Williams in an alley in Harrisburg, PA, December 15, 1995.
- Walker and Johnson were tried jointly; Johnson’s liability arose from accomplice and conspiracy statutes under Pennsylvania law.
- Trial testimony showed Walker’s threats to kill Williams and Johnson’s presence during earlier debt-collection confrontation.
- Witnesses described Williams being escorted toward an alley where a shotgun was fired; a shotgun with a missing barrel was found at the scene.
- The Third Circuit reversed, holding the evidence insufficient under Jackson v. Virginia and requiring reweighing of inferences.
- The Supreme Court granted certiorari and reversed, holding the evidence was constitutionally sufficient under the Jackson framework and deferential AEDPA review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to convict Johnson as accomplice/co-conspirator | Johnson argues evidence fails under Jackson | Commonwealth contends evidence supports liability | Evidence sufficient under Jackson and AEDPA standards |
Key Cases Cited
- Cavazos v. Smith, 565 U.S. 1 (2011) (deferential standard on habeas review; two layers of deference)
- Renico v. Lett, 559 U.S. _ (2010) (AEDPA deference applies to state-court sufficiency rulings)
- Commonwealth v. McFarland, 452 Pa. 435, 308 A.2d 592 (Pa. 1973) (source for permissible inferences in Pa. law)
- Commonwealth v. Bostick, 958 A.2d 543 (Pa. Super. 2008) (principles on inferential reasoning and jury factfinding)
- Commonwealth v. Montalvo, 598 Pa. 263, 956 A.2d 926 (Pa. 2008) (conspiracy liability for overt acts in furtherance of an agreed crime)
