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Name: Coleman v. Johnson
Case #: 11-1053
Court: US Supreme Court
District USSup
Opinion Date: 05/29/2012
Subsequent History: 132 S.Ct. 2060; 182 L.Ed.2d 978

A federal court may not overturn a state court’s rejection of a criminal defendant’s sufficiency of the evidence challenge unless the state court’s finding was “objectively unreasonable.” Johnson was convicted as an accomplice and coconspirator in a 1995 slaying. His conviction was affirmed in state court. On Johnson’s habeas petition, the Third Circuit reversed his conviction, finding the evidence at trial insufficient. The United States Supreme Court reversed. Sufficiency claims face a high bar in federal habeas proceedings. On direct appeal, it is the trier of fact’s responsibility to draw conclusions from the evidence. Such findings may be set aside only if no rational trier of fact could have agreed with the fact finder. On habeas review, a federal court may only overturn a conviction based on insufficient evidence if the state court decision was “objectively unreasonable.” Under Jackson v. Virginia (1979) 443 U.S. 307, federal courts must look to state law for the substantive elements of the offense. However, the question whether the evidence proved the offense as required by due process is a matter of federal law. The only question under Jackson is whether the jury’s finding was so insupportable as to fall below the threshold of bare rationality. Here, the state court of last review did not think so, and that determination in turn is entitled to considerable deference under AEDPA. The evidence at Johnson’s trial was sufficient to withstand a due process challenge under Jackson.