Jackson v. Virginia

1979

Court: US Supreme Court

Facts: Strange facts involving drunkenness, plans for a sexual encounter, and a sheriff offering to hold on to the gun. Anyway, the girlfriend got killed, and Jackson claims it was accidental.

Posture: Convicted at trial, motion to set aside the conviction denied.

Issue: Can federal courts grant habeas corpus relief based on in

Holding: Feds can review the evidence, but in this particular case, it was totally reasonable that Jackson got found guilty.

Rule: If the trial court could reasonably find as it did, based on construing the evidence in the prosecution's favor, defer to the trial court. Otherwise, the federal court does have the power to grant relief if no court could have rationally found the defendant guilty beyond a reasonable doubt.

Reasoning: In Thompson v. Louisville the court adopted the "no evidence" doctrine, meaning that the question on review was "does the record contain any evidence at all to support the state's conviction" instead of "is it possible for the evidence to convince a rational trier of fact beyond a reasonable doubt." After Winship, the Thompson "no evidence" rule is inadequate to protect against misapplication of the constitutional standard of reasonable doubt.

Dicta: