When can a federal court overturn a state court conviction?
In a per curiam decision, the U.S. Supreme Court has reinstated a conviction stemming from a 1995 murder, reversing the Third Circuit Court of Appeal’s decision on the matter. The high court held that it was for juries, and not judges, to decide whether to convict someone based on evidence presented at trial.
The Third Circuit Court of Appeals granted habeas relief to inmate Lorenzo Johnson after his 1995 conviction in the shooting death of Taraja Williams. Johnson was convicted as an accomplice and co-conspirator.
In its ruling, the Third Circuit court found that there was insufficient evidence presented at trial to convict Johnson on charges of first degree murder and conspiracy.
Johnson and Corey Walker were together on the night of the killing. Walker was allegedly the man who pulled the trigger. Earlier, Walker had tried to collect on a debt from Williams. Williams retaliated, beating Walker with a broomstick. Walker and Johnson returned with a vengeance and during a subsequent confrontation, Walker shot Williams. Witnesses claim to have seen three people entering an alley.
The issue on Johnson's appeal was that he did not have the requisite specific intent to commit murder. The court held that with the evidence presented, he may only have intended to confront or harass the victim. The court claimed that the witness testimony failed to show that the victim was forced into the alley.
But the Supreme Court differed with this analysis, saying that the coercion in that situation could easily have been inferred from other circumstances, particularly the fact that Walker was carrying a noticeably concealed weapon.
The standard for overturning a state court conviction by a federal court is objective reasonableness, SCOTUS said. A decision of a state court upholding a conviction may not be overturned by the federal courts unless the conviction was objectively unreasonable.