503 F. App'x 749
11th Cir.2013Background
- Jones, a Florida state prisoner proceeding pro se, appeals the district court’s dismissal of his 28 U.S.C. § 2254 petition.
- Jones asserted that the state trial court’s denial of his motion for a judgment of acquittal violated federal due process.
- The district court denied the petition; on appeal, Jones contends the state court’s decision was based on an unreasonable factual determination regarding his knowledge of the gun.
- Review is de novo on whether the state court decision was contrary to clearly established federal law, an unreasonable application of federal law, or an unreasonable determination of facts under AEDPA.
- Under AEDPA, relief is granted only if the state court’s decision is contrary to federal law or unreasonably determined in light of the evidence.
- Florida law defines felon in possession as (1) a prior felony conviction and (2) knowingly owning or having a gun in one’s care, custody, or control; federal review asks whether any rational trier of fact could find the elements beyond a reasonable doubt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence for felon in possession | Jones argues the state court unreasonably determined facts about knowledge of the gun. | State contends the evidence, viewed favorably to the state, supports knowledge and possession. | Evidence was sufficient; a rational trier of fact could find the elements beyond a reasonable doubt. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency review for due process requiring rational basis for verdict)
- Coleman v. Johnson, 566 U.S. __ (2012) (two-layer deference in habeas; threshold rationality standard)
- Owen v. Fla. Dep’t of Corr., 686 F.3d 1181 (11th Cir. 2012) (AEDPA review framework for unreasonable factual determinations)
- Green v. Nelson, 595 F.3d 1245 (11th Cir. 2010) (liberal construction of pro se habeas petitions)