Mark Anderson v. Deanna Brookhart
19f4th980
| 7th Cir. | 2021Background
- Around 2:00 a.m. in 2008, Mark Anderson went to a Chicago sandwich shop with two companions; an argument between Anderson and customer Darryl Hart led Anderson to shoot Hart multiple times, killing him.
- Ozier Hazziez was outside the shop, saw the shooting, ran to his car, got in and drove off; as he left he heard approximately three additional shots.
- A jury convicted Anderson of first-degree murder (Hart), attempted first-degree murder (Hazziez), and aggravated discharge of a firearm toward a vehicle occupied by Hazziez; the attempted-murder and aggravated-discharge counts were merged at sentencing.
- The Illinois Appellate Court affirmed the murder conviction, reversed the attempted-murder conviction for an erroneous instruction (the State declined retrial), and later affirmed the aggravated-discharge conviction on appeal.
- Anderson filed a federal habeas petition arguing insufficient evidence supported the aggravated-discharge conviction because the state court unreasonably inferred (1) he shot at Hazziez and (2) Hazziez was in the car when Anderson fired; the district court denied relief and a certificate of appealability issued.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for aggravated discharge (did Anderson knowingly discharge a firearm toward a vehicle occupied by a person?) | Anderson: State appellate court unreasonably inferred (a) he shot at Hazziez rather than someone else and (b) the shots occurred while Hazziez was in his car. | State: Cooper's grand jury testimony and written statement plus Hazziez's testimony support those inferences; a rational jury could find the elements beyond a reasonable doubt. | Court: Affirmed—Illinois Appellate Court reasonably applied Jackson; evidence sufficed. |
| Alleged contradiction between two Illinois Appellate Court decisions | Anderson: Two appellate decisions conflict, rendering the later decision unreasonable. | State: The first opinion did not address the aggravated-discharge sufficiency; the second independently assessed the issue. | Court: No contradiction; later decision was not unreasonable. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (evidence sufficient if any rational trier of fact could find essential elements beyond a reasonable doubt)
- Schriro v. Landrigan, 550 U.S. 465 (2007) (AEDPA requires deference; federal court must not grant habeas relief unless state decision was unreasonable)
- Wilson v. Sellers, 138 S. Ct. 1188 (2018) (federal review focuses on specific reasons given by the state court)
- Coleman v. Johnson, 566 U.S. 650 (2012) (Jackson review presumes trier of fact resolved conflicts in prosecution's favor; federal court must ask if any rational trier could have found guilt)
- Cavazos v. Smith, 565 U.S. 1 (2011) (federal courts cannot overturn state sufficiency rulings simply because they disagree)