Magraw v. Roden, 743 F.3d 1

Magraw was convicted of second-degree murder for his wife Nancy Magraw's death during a 1990 retirement/divorce period; autopsy showed strangulation.
The defense argued natural causes or non-killer theory; the jury rejected these theories at the second trial.
Magraw appealed to MAC, then Mass. Supreme Judicial Court; federal habeas corpus followed after district court proceedings.
The district court denied relief; the First Circuit reviews under AEDPA de novo on merits when state court adjudicated on the merits.
Key issues framed: sufficiency of the evidence, spoliation of the larynx, and prosecutorial misconduct; district court outcomes aligned with MAC.
The First Circuit affirms, holding MAC reasonably applied Jackson v. Virginia and that no due process violation occurred.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of cause of death evidence	Magraw argues equal evidence favors innocence on cause of death.	MAC properly credited Commonwealth experts; death by strangulation supported.	Yes; MAC reasonably applied Jackson; evidence supported strangulation theory.
Sufficiency of identity evidence	Circumstantial evidence insufficient to prove Magraw killed wife.	Circumstantial evidence with motive/opportunity suffices; not require direct evidence.	Yes; circumstantial evidence adequate; jury could infer guilt.
Spoliation of larynx evidence	Destruction of larynx violated due process under Trombetta/Youngblood.	Youngblood controls; evidence would be only potentially exculpatory with no bad faith.	No; Youngblood/Trombetta do not require suppression; no due process violation.
Prosecutorial misconduct linkage to due process	Prosecutor's comments about prior trial and rifle on bed tainted trial.	Statements were isolated or harmless in context; MAC adjudicated merits.	No; MAC's ruling on merits not unreasonable; no due process violation.

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of evidence on appeal)
Cavazos v. Smith, 132 S. Ct. 2 (2011) (reaffirmed deferential review of state-court findings under Jackson)
O'Laughlin v. O'Brien, 568 F.3d 287 (1st Cir. 2009) (circumstantial evidence standards in habeas review)
O'Brien v. United States, 14 F.3d 703 (1st Cir. 1994) (direct evidence not required for conviction; deferential review)
Morgan v. Dickhaut, 677 F.3d 39 (1st Cir. 2012) (how to view conflicting inferences in Jackson-based review)
Leftwich v. Maloney, 532 F.3d 20 (1st Cir. 2008) (standard for evaluating circumstantial evidence and inferences)
Donnelly v. DeChristoforo, 416 U.S. 637 (1974) (due process standard for prosecutorial misconduct on habeas review)
Darden v. Wainwright, 477 U.S. 168 (1986) (test for prosecutorial misconduct in trial fairness)
Trombetta v. Trombetta, 467 U.S. 479 (1984) (due process and preservation of exculpatory evidence standard)
Arizona v. Youngblood, 488 U.S. 51 (1988) (due process when evidence is only potentially exculpatory; bad faith requirement)
Olszewski v. Spencer, 466 F.3d 47 (1st Cir. 2006) (irreplaceability and evidence preservation considerations)
Illinois v. Fisher, 540 U.S. 544 (2004) (Trombetta-Youngblood framework referenced)
Zulloaga v. Spencer, 585 F.3d 27 (1st Cir. 2009) (AEDPA adjudication on the merits framework)