Jamar Travillion v. Superintendent Rockview SCI, 982 F.3d 896

On Feb. 24, 2003, Rainbow Apparel manager Deborah Diodati was robbed at gunpoint; the robber carried a Manila folder in his left hand, forced her to open two safes, and fled to a waiting Ford Taurus. ~ $7,000 stolen.
The robber’s face was covered; Diodati never saw his bare face or bare hands and gave only a general description (voice suggested African‑American; estimated height ~5'9"–5'10").
Investigators recovered a Manila folder and loose paper at the scene; latent fingerprints from the left hand on the folder and one paper were identified as belonging to Travillion. No other prints of his were found; the fingerprint examiner could not date when prints were made.
No evidence tied Travillion to the car, the proceeds, clothing, shoes, or knowledge of the store’s internal safe; no testimony that the robber’s hands were bare or that the folder could not have been touched earlier.
Travillion was convicted of robbery, sentenced (10–20 years consecutive to an existing life sentence), exhausted state appeals, and sought federal habeas relief. The Third Circuit granted habeas, holding the state court unreasonably applied Jackson v. Virginia and ordering the writ with prejudice to reprosecution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to identify perpetrator	Travillion: fingerprints on a movable folder/paper, without proof when impressed and with contradictory witness description, are insufficient to prove he was the robber beyond a reasonable doubt	Commonwealth: left‑hand prints on the folder and Diodati’s testimony that the robber held the folder in his left hand suffice to identify Travillion	Court: Reversed — under Jackson, prints on a readily movable object without evidence of timing plus lack of other incriminating evidence are too speculative to sustain conviction; habeas granted
Confrontation Clause violation	Travillion raised an alternative Confrontation Clause claim on appeal	Commonwealth defended conviction on state‑court rulings	Not reached — court granted relief on sufficiency grounds and did not decide confrontation claim
Remedy / double jeopardy	Travillion argued that reversal for insufficient evidence bars retrial	Commonwealth implicitly argued remedy should not preclude reprosecution	Court ordered writ with prejudice to reprosecution, relying on Burks and related authority

Jackson v. Virginia, 443 U.S. 307 (1979) (Jackson standard: evidence insufficient if no rational juror could find guilt beyond a reasonable doubt)
Mikes v. Borg, 947 F.2d 353 (9th Cir. 1991) (fingerprints on movable objects require evidence of when impressions were made; otherwise conviction is speculative)
United States v. Strayhorn, 743 F.3d 917 (4th Cir. 2014) (fingerprint on movable item insufficient absent evidence on timing or additional incriminating evidence)
Commonwealth v. Hunter, 338 A.2d 623 (Pa. Super. 1975) (fingerprint on relatively immovable, inaccessible surface with evidence of recency can support conviction)
Commonwealth v. Cichy, 323 A.2d 817 (Pa. Super. 1974) (prints on readily movable/common items present too great a possibility of innocent contact to sustain conviction)
Burks v. United States, 437 U.S. 1 (1978) (reversal for insufficient evidence bars retrial; remedy is acquittal)
O'Laughlin v. O'Brien, 568 F.3d 287 (1st Cir. 2009) (followed Burks in directing release with prejudice after habeas reversal for insufficiency)