Todd Saxon v. Jacqueline Lashbrook, 2017 U.S. App. LEXIS 20392

In 1995, the body of 12-year-old O.W. was found in a burned garage; autopsy showed she had been sexually assaulted and stabbed to death before the fire.
Todd Saxon, who had frequented the victim’s home and later admitted to having sex with her days before her disappearance, was indicted in 2002 for first-degree murder, arson, and concealment of homicide; his DNA matched sperm recovered from the victim.
At trial the State presented testimony about Saxon’s presence at the household on the night of disappearance, the lack of forced entry, forensic evidence of accelerant and fire, autopsy and DNA results, and prior investigative interviews where Saxon initially gave varying accounts and delayed providing blood samples.
A jury convicted Saxon in 2005; the Illinois Appellate Court affirmed his conviction on direct appeal, finding the evidence sufficient under Jackson v. Virginia.
Saxon filed a federal habeas petition under 28 U.S.C. § 2254 asserting, among other claims, that the evidence was insufficient; the district court denied relief and this appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence under Jackson v. Virginia	Saxon argued the evidence was insufficient to support convictions beyond a reasonable doubt	State argued that DNA match, Saxon’s admissions, his presence/opportunity, and circumstantial evidence sufficed for a rational jury to convict	Court held the Illinois Appellate Court reasonably applied Jackson; evidence was sufficient and AEDPA deference precludes relief
Timeliness of notice of appeal	Saxon contended his notice was timely under the mailbox rule despite misfiling to the court of appeals	State argued the notice was untimely because the court of appeals received it after the deadline	Court held the mailbox rule (Fed. R. App. P. 4(c)(1)) and mistaken-filing rule (Rule 4(d)) together rendered the notice timely

Cullen v. Pinholster, 563 U.S. 170 (2011) (AEDPA review is highly deferential and difficult to meet)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence: whether any rational trier of fact could find guilt beyond reasonable doubt)
Coleman v. Johnson, 566 U.S. 650 (2012) (federal courts may not overturn state-court sufficiency findings unless objectively unreasonable)
Renico v. Lett, 559 U.S. 766 (2010) (§ 2254(d) requires objectively unreasonable application of federal law)
Makiel v. Butler, 782 F.3d 882 (7th Cir. 2015) (standard of review for district court denials of habeas petitions)
Jones v. Butler, 778 F.3d 575 (7th Cir. 2015) (habeas sufficiency challenges typically reviewed under § 2254(d)(1))
Rodriguez v. Gossett, 842 F.3d 531 (7th Cir. 2016) (description of objectively unreasonable standard in AEDPA context)
Jackson v. Frank, 348 F.3d 658 (7th Cir. 2003) (discussion of limits on overturning state-court sufficiency findings)