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Name: Juan H. v. Allen
Case #: 04-15562
Court: US Court of Appeals
District 9 Cir
Opinion Date: 06/02/2005
Summary

A minor committed to the California Youth Authority for first degree murder and attempted first degree murder was entitled to federal habeas relief where the record contained insufficient evidence to show that he harbored the intent necessary for conviction under a theory of aiding and abetting. The Ninth Circuit held that the California Court of Appeal’s affirmance constituted an unreasonable application of the Fourteenth Amendment requirement that the prosecution present evidence sufficient to prove every element of the crime beyond a reasonable doubt. Here, the record contained insufficient evidence to show that the minor knew his brother intended to commit first degree murder or that he acted in a way intended to encourage or facilitate those killings. The court reversed and remanded with instructions to grant the writ of habeas corpus. The court rejected, however, the minor’s argument that the Miranda warnings given during his interrogation were ineffective because they were preceded by an officer’s statement that the warnings were required under the law. The court further rejected the argument that trial counsel was ineffective for failing to argue that the minor’s statement was coerced. The court noted that a videotape of the interrogation showed that the minor never broke down under questioning, never made any admissions, and effectively invoked his right to an attorney in the midst of questioning, all factors tending to show that his will was not overborne by coercion.