Thursday, January 31, 2013

Cavazos v. Smith case brief

Cavazos v. Smith
132 S. Ct. 2

PROCEDURAL POSTURE: Respondent inmate petitioned for a writ of habeas corpus pursuant to 28 U.S.C.S. § 2254, asserting a claim of insufficient evidence regarding her conviction under Cal. Penal Code § 273ab. The district court denied the petition. The United States Court of Appeals for the Ninth Circuit reversed with instructions to grant the writ. Petitioner warden sought review, and certiorari was granted.

OVERVIEW: The inmate's seven-week-old grandchild died. The prosecution's three experts attested that the child's death was the result of shaken baby syndrome (SBS). One defense expert testified that the child died from old brain trauma. The other defense expert testified that the child's death was due to sudden infant death syndrome (SIDS). The jury found the inmate guilty. In seeking habeas relief, the inmate argued that the evidence was insufficient to prove that the child died of SBS. The United States Supreme Court determined that the federal appellate court erred in granting the inmate's habeas petition because the evidence presented at trial supported the jury's decision since, inter alia, the affirmative indications of trauma formed the basis of the experts' opinion that the child died from shaking so severe that his brainstem tore. The federal appellate court improperly substituted its judgment for that of the jury on the question whether the prosecution's expert witness or the defense's expert witness more persuasively explained the cause of death.

OUTCOME: The Court granted the inmate's petition for a writ of certiorari and motion to proceed in forma pauperis. The Court reversed the appellate court's judgment and remanded the case for further proceedings. 6-3 per curiam decision; 1 dissent.

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