Coleman v. Johnson

In reviewing a criminal conviction, a reviewing court may only set aside a jury verdict due to insufficient evidence “if no rational trier of fact could have agreed with the verdict." It is the jury’s responsibility to draw inferences and conclusions from the evidence offered at trial and deference must be given.

Respondent witnessed a murder and was convicted as an accomplice and co-conspirator. After exhausting all state remedies, Respondent filed for a writ of habeas corpus in Federal District Court under 28 U.S.C. § 2254. The District Court denied habeas relief, but the Court of Appeals for the Third Circuit reversed, finding there was no reasonable basis to conclude that Respondent had the specific intent to aid in the murder.

The Supreme Court reversed, and reiterated the ruling in Cavazos v. Smith, 565 U.S. 1 (2011), which stated that a reviewing court may only set aside a jury verdict on the basis of insufficient evidence "if no rational trier of fact could have agreed with the jury."The Supreme Court held that the Court of Appeals for the Third Circuit failed to recognize the role of the jury and the deference to the jury that is required. Federal law provides juries discretion when deciding what inferences to make from the evidence. The record indicated facts that went far beyond the rational basis standard laid out in Cavazos, and supported a conviction for accomplice and co-conspiracy to murder.