Connors v. Grenier
16-1461U
| 1st Cir. | Nov 15, 2017Background
- Charlene Connors was convicted in Massachusetts of embezzlement; she appealed and later sought federal habeas relief.
- Connors argued the Commonwealth failed to prove she had the specific intent to gain an undue advantage (an element of embezzlement under Massachusetts law).
- She also challenged the trial judge’s jury instructions defining "fiduciary," arguing they were legally improper and prejudicial.
- The district court denied her §2254 habeas petition, finding the evidence sufficient and the instructions not so flawed as to violate due process.
- The First Circuit reviewed de novo the district court’s denial under 28 U.S.C. §2254(d) and affirmed for substantially the same reasons stated by the district court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence (specific intent) | Connors: Commonwealth failed to prove she knowingly acted to gain an undue advantage | Commonwealth: Evidence and reasonable inferences suffice to show Connors knowingly participated in embezzlement | Affirmed — a rational jury could find intent beyond a reasonable doubt; no conflict with Jackson standard |
| Jury instructions (definition of "fiduciary") | Connors: Instructions were legally flawed and "infected" the trial, violating due process | Commonwealth: Instructions, taken in context, did not remove jury factfinding or direct a verdict | Affirmed — instructions, though inartful, did not so taint the trial as to violate Estelle/Cupp due process standard |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence review in criminal cases)
- Estelle v. McGuire, 502 U.S. 62 (1991) (due process governs whether erroneous jury instructions require habeas relief)
- Cupp v. Naughten, 414 U.S. 141 (1973) (instructional error requires reversal only if it so infects the trial as to deprive due process)
- Linton v. Saba, 812 F.3d 112 (1st Cir. 2016) (discussing Massachusetts application of Jackson sufficiency standard)
- Commonwealth v. Linton, 924 N.E.2d 722 (Mass. 2010) (Massachusetts articulation of sufficiency review)