Smith v. Cavazos
667 F.3d 1308
9th Cir.2010Background
- Smith was convicted in California state court of assault on a child resulting in death.
- California Court of Appeal affirmed; California Supreme Court denied review.
- Smith filed a federal habeas petition asserting due process violation for insufficient evidence.
- District Court denied; Ninth Circuit reversed and issued a writ in 2006 (Smith v. Mitchell).
- Supreme Court granted certiorari, vacated the judgment, and remanded for reconsideration in light of Carey v. Musladin and related cases.
- On remand, the Ninth Circuit reaffirmed the Jackson v. Virginia determination and reinstated its prior judgment, then Brown v. Brown prompted another Supreme Court review, which ultimately upheld reinstatement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the state-court denial of insufficiency of evidence was objectively unreasonable under Jackson | Smith argues insufficiency cannot support guilt beyond reasonable doubt | Mitchell argues evidence was sufficient under Jackson | Writ issued; state court unreasonable under Jackson |
| Whether Brown v. Brown undermines the Smith decision | Brown would cast doubt on Smith's reasoning | Brown does not undermine Smith's rationale | Brown does not cast doubt; Smith reinstated |
| Whether posttrial Mueller Report evidence could affect Jackson analysis | Mueller Report could be used to supplement trial record | Posttrial evidence was improper to consider under Jackson | Not applicable to Smith; reliance remained on trial record |
| Whether the double deference under AEDPA affects the result | Deference still warrants habeas relief given unreasonable application | Deference supports state-court findings | Double deference acknowledged; nonetheless, application deemed unreasonable; writ issued |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (insufficiency standard for capital/fact finding in habeas review)
- Carey v. Musladin, 549 U.S. 70 (U.S. 2006) (relevant to due process and courtroom reminders and prejudicial error)
- Schriro v. Landrigan, 550 U.S. 465 (U.S. 2007) (impact of post-conviction developments on review)
- Wright v. Van Patten, 552 U.S. 120 (U.S. 2008) (limitation on federal review of state-court factual determinations)
- McDaniel v. Brown, 130 S. Ct. 665 (2010) (DNA-evidence case; clarifies effect of new evidence on Jackson analysis)
- Williams v. Taylor, 529 U.S. 362 (U.S. 2000) (double deference under AEDPA and Jackson)