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Sufficiency of the Evidence

Once again, the U.S. Supreme Court has unanimously and summarily reversed a grant of habeas corpus by a circuit divisible by three, a grant that followed denial of the claim by every court to consider it.  Once again, the case involves the sufficiency-of-the-evidence rule of Jackson v. Virginia.

In Harrisburg, Pennsylvania, Taraja Walker was murdered by Corey Williams.  The jury found, beyond a reasonable doubt, that Lorenzo Johnson was an accomplice.  Was the evidence sufficient to sustain that verdict?  The trial judge thought so.  The Pennsylvania intermediate appellate court thought so.  The Pennsylvania Supreme Court denied review.  The federal district court denied habeas.  The Third Circuit disagreed with all the prior courts, and today the Supreme Court reversed that decision.

The jury in this case was convinced, and the only question under Jackson is whether that finding was so insupportable as to fall below the threshold of bare rationality. The state court of last review did not think so, and that determination in turn is entitled to considerable deference under AEDPA, 28 U. S. C. ยง2254(d).

Affording due respect to the role of the jury and the state courts, we conclude that the evidence at Johnson's trial was not nearly sparse enough to sustain a due process challenge under Jackson. The evidence was sufficient to convict Johnson as an accomplice and a co-conspirator in the murder of Taraja Williams.

The case is Coleman v. Johnson, No. 11-1053.

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