The question is in regards to the case of Jackson v. Virginia, 443 U.S. 307,99 S. Ct 2781
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The Court held in the Jackson case that there was sufficient evidence to uphold the petitioner's conviction. The Court found from the evidence that the Petitioner (who claimed self defense or alternatively that he was too intoxicated to have formed the necessary intent to commit premeditated murder) shot the victim twice after he had taken the time to reload his gun (having first fired it into the ground.) The two shots were fired at close range by one experienced in the use of the firearm. Also, after the shooting, the Petitioner drove the Victim's vehicle from Virginia to North Carolina without mishap, which contradicted his claim of extreme intoxication. Accordingly, the Court found, correctly, that the defendant had the capacity to form and did form an intent beforehand to commit murder.
Pohnpei makes some good observations, but I would question whether Jackson had to prove his accounts to be true, or would the prosecution have needed to prove it was not true? Everything else seems pretty well founded on what a rational observer could verify, and it's clear that Jackson had enough where withall to stop and reload.
The Supreme Court's only charge in this case is to decide whether any rational factfinder could find the defendant guilty beyond a reasonable doubt that the killing was premeditated. The Supreme Court did not have to find that the defendant was guilty -- just that a rational person could find him guilty.
With that standard in mind, I believe that the Supreme Court ruled correctly. A rational observer could surely find that Jackson did not act in self-defense because it is (from what I have read) not at all clear that his account of having been threatened, having fired the warning shots, etc, is true.
A rational observer could also find that he was sober enough to form the intent necessary for first degree murder. You had a police officer speak to Jackson and the officer could, presumably, have provided evidence as to how drunk Jackson was.
So this is not a case of having to decide Jackson's guilt -- it's just a case of having to decide if anyone could rationally find him guilty. I think that they could rationally find him guilty and, therefore, the Court acted properly.
In short the answer is no or better yet it should have been no. This was a collateral attack by Jackson for his conviction of murder. After he exhausted his direct appeals, he filed a habeas corpus petition in the federal court looking to attack his conviction as being against federal constitutional protections. Jackson won the battle in so far as he persuaded the Court to adopt a new standard of review in habeas cases. Federal courts could now look into and review the facts adduced at trial and determine independently whether the facts were sufficient to support the conviction.
The old standard of review was whether the record was devoid of any evidence of guilt. This was a fairly black/white standard. One that wasnot readily subject to ideological manipulation. The new standard permits a federal judge to substitute his or her judgment for that of the trier of fact.
The problem is that after a number of state judges review a defendant's conviction it only takes one federal judge to see it differently and and declare a defendant's conviction unconstitutional. The mischief incident with such a standard has served to fulfill Justice Steven's prophecy that habeas petitions among other things would soon overburden the court system as well as reduce confidence in a justice system that has no finality.
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