Sunday, November 3, 2013

Jackson v. Virginia case brief

Jackson v. Virginia case brief summary
443 U.S. 307 (1979)

Petitioner inmate was convicted after a state bench trial of first degree murder. The Court of Appeals for the Fourth Circuit reversed the district court's grant of habeas corpus relief on the basis that there was no evidence of premeditation because some evidence existed that the inmate intended to kill the victim. The inmate was granted certiorari.

The inmate claimed that a federal habeas court did not have to consider whether there was any evidence to support his state court conviction, but had to determine whether there was sufficient evidence.

  • The Court held that, assuming the procedural prerequisites were satisfied, the inmate was entitled to habeas relief if there was evidence that no rational trier of fact could have found proof of guilt beyond a reasonable doubt. 
  • The Due Process Clause of the Fourteenth Amendment protected a criminal defendant against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime charged. 
  • A state prisoner who alleged the evidence could not be fairly characterized as sufficient to have led a rational trier of fact to find guilt beyond a reasonable doubt stated a constitutional claim cognizable in a federal habeas proceeding. 
  • Review of the record in the light most favorable to the prosecution established a rational fact finder could readily have found the inmate guilty beyond a reasonable doubt of first degree murder under state law.


The judgment of the appellate court reversing the district court's order granting habeas corpus relief to the inmate was affirmed.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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