Hattie Tanner v. Joan Yukins, 867 F.3d 661

Background

Victim Sharon Watson was stabbed in Barney’s Bar basement after 1:00 a.m. on March 22, 1995; evidence suggested robbery and a struggle.
Police later found blood at the upstairs sink (type B, PGM 2+1+), a knife, and other items; forensic testing produced limited DNA results (blood on victim’s shirt matched an unknown female; basement DNA excluded Tanner).
Tanner (African American) was investigated; detectives recorded/interviewed her and testified she said she waited in a car while an associate entered Barney’s and that a pictured knife was hers, though recorded transcript and Tanner’s trial testimony contradicted or qualified those statements.
Defense requested funds to consult/hire a serology/DNA expert; trial court denied the request, concluding available prosecution evidence largely excluded Tanner for basement DNA and that consultation would not change that. Michigan Court of Appeals reversed on the expert-funding issue and for insufficiency as to aiding-and-abetting theory; Michigan Supreme Court reinstated the felony-murder conviction in a short per curiam opinion.
On federal habeas review, the Sixth Circuit considered two claims (Ake/Due Process expert-funding claim; Jackson sufficiency-of-the-evidence claim) and held that the Michigan Supreme Court unreasonably applied Jackson — vacating the conviction and directing unconditional release; the court did not reach the Ake claim because Jackson relief was granted.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Michigan Supreme Court unreasonably applied Jackson v. Virginia to uphold Tanner’s murder conviction	Tanner: evidence was insufficient because inculpatory facts were weak (ambiguous statements, remote prior possession of knife, blood type match not unique) and strong exculpatory evidence existed (unknown woman’s blood on victim’s shirt; witnesses saw strangers near bar)	State: jury verdict should be upheld; evidence (Tanner’s statements and serology match at sink) allowed a rational juror to convict	Court: Reversed — Michigan Supreme Court unreasonably applied Jackson; evidence insufficient beyond a reasonable doubt, so habeas relief granted and conviction set aside
Whether the trial court violated Ake by denying funds for a serology/DNA expert	Tanner: needed expert assistance to understand and rebut prosecution’s serology/DNA evidence; indigent defendant entitled to expert under Ake when necessary to present defense	State: prosecution’s testing largely excluded Tanner from basement DNA and trial counsel could rely on cross-examination of prosecution experts; funds not necessary	Court: Did not decide the Ake claim on the merits because sufficient relief was granted on Jackson claim
Whether AEDPA deference bars federal habeas relief on state-court sufficiency determination	Tanner: Michigan Supreme Court’s application of Jackson was objectively unreasonable despite AEDPA deference	State: federal habeas must defer to state-court ruling unless it was contrary to or an unreasonable application of clearly established federal law	Court: Applied AEDPA standard and concluded Michigan Supreme Court unreasonably applied Jackson; relief warranted
Remedy on successful Jackson habeas claim	Tanner: requests vacatur and release	State: likely would oppose unconditional release absent retrial	Court: Ordered writ granting unconditional release (set aside conviction and free from state supervision)

Key Cases Cited

Ake v. Oklahoma, 470 U.S. 68 (1985) (indigent defendant entitled to access to psychiatric expert when necessary for due process)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence: whether any rational trier of fact could find guilt beyond a reasonable doubt)
Williams v. Taylor, 529 U.S. 362 (2000) (AEDPA standard: federal habeas relief only if state court decision is contrary to or an unreasonable application of Supreme Court precedent)
Newman v. Metrish, 543 F.3d 793 (6th Cir. 2008) (discussion of standard of review on habeas sufficiency claims)