History
  • No items yet
midpage
Coleman v. Johnson
132 S. Ct. 2060
| SCOTUS | 2012
Read the full case

Background

  • 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)
Read the full case

Case Details

Case Name: Coleman v. Johnson
Court Name: Supreme Court of the United States
Date Published: May 29, 2012
Citation: 132 S. Ct. 2060
Docket Number: 11-1053
Court Abbreviation: SCOTUS