Martell v. Hill, 3:18-cv-00290

On August 27, 2011 Maurillo ("Maurillo") Garcia was chased and violently attacked near Ezie St.; he later died of multiple stab wounds and blunt‑force trauma. Several witnesses described a group assault involving 5–7 men.
Tommy Gonzalez (cooperating witness) testified he, Martell (Petitioner), Mendoza and Ramirez ran from 436 Ezie St. toward Garcia; Tommy described punches and weapons being passed afterward.
Salvador Rivas, an eyewitness in a nearby garage, testified he saw a group chase and collectively beat the victim; he acknowledged poor lighting and ~60 yards distance.
Physical evidence placed Martell at the scene (phone linked to location, fingerprint on beer can, DNA on a cigarette); Martell had scratches on his hands and left with the others after the assault.
Martell was convicted in California state court of second‑degree murder and a gang enhancement; the California Court of Appeal affirmed. Martell sought federal habeas relief arguing insufficiency of evidence under the natural‑and‑probable‑consequences theory.
The district court denied the § 2254 petition, applying AEDPA deference to the state appellate decision and also denied a certificate of appealability.

Issue	Martell's Argument	Respondent's Argument	Held
Sufficiency of evidence to support second‑degree murder (natural‑and‑probable‑consequences)	Rivas’s testimony was not credible as a matter of law (poor lighting, long distance); Martell only knew Barragan and thus could not be proven to have aided/known co‑perpetrators’ intent	The jury reasonably could credit Rivas; multiple corroborating facts (Tommy’s ID, physical evidence, flight, scratches, gang context) support aider/abettor and foreseeability that assault could lead to murder	Denied. Applying Jackson and AEDPA, the state court’s conclusion that a rational jury could find Martell guilty was not objectively unreasonable.
Certificate of Appealability (COA)	Relief is meritorious and debatable	No reasonable jurist would find district court's assessment debatable	Denied. COA will not issue.

In re Winship, 397 U.S. 358 (1970) (due process requires proof beyond a reasonable doubt of every element)
Jackson v. Virginia, 443 U.S. 307 (1979) (evidence sufficiency standard — whether any rational trier of fact could have found guilt beyond a reasonable doubt)
Williams v. Taylor, 529 U.S. 362 (2000) (AEDPA standard: contrary to or unreasonable application of clearly established federal law)
Ylst v. Nunnemaker, 501 U.S. 797 (1991) (look‑through rule for last reasoned state decision)
Wilson v. Sellers, 138 S. Ct. 1188 (2018) (presume later unexplained state order adopted rationale of last reasoned decision)
Coleman v. Johnson, 566 U.S. 650 (2012) (federal habeas courts must defer to jury credibility determinations)
Wright v. West, 505 U.S. 277 (1992) (reviewing courts must presume factfinder resolved conflicts in prosecution’s favor)
Bruce v. Terhune, 376 F.3d 950 (9th Cir. 2004) (juries entitled to near‑total deference on credibility)
Boyer v. Belleque, 659 F.3d 957 (9th Cir. 2011) (federal habeas relief requires state court determination to be objectively unreasonable)
Slack v. McDaniel, 529 U.S. 473 (2000) (standard for certificate of appealability)