Wright v. West
Decided on June 19, 1992; 505 US 277


I. ISSUES II. CASE SUMMARY III. AMICI CURIAE IV. DECISION V. WIN OR LOSS?
I. ISSUES:

A. Issues Discussed:  Criminal Justice (procedure), habeas corpus, due process

B. Legal Question Presented:

Did the Court of Appeals for the Fourth Circuit correctly apply the decision in Jackson v. Virginia, 443 US 307 (1979), in concluding that the evidence against respondent Frank West was insufficient, as a matter of due process, to support his state court conviction for grand larceny?
II. CASE SUMMARY:

A. Background:

Several of the items missing from a burglarized home were recovered by police from the home where Mr. West (Respondent) and his wife lived. Respondent was arrested and charged with grand larceny. During his testimony, he admitted to a prior felony conviction, but denied having taken anything from the burglarized home, explaining that he frequently bought and sold merchandise at various flea markets. He offered no explanation for how he had acquired any of the stolen items until cross-examination, when he gave vague, evasive, and even contradictory answers. He could not remember how he acquired several major items, including a television set and a coffee table; and failed to produce any evidence corroborating his story.

Respondent was found guilty and convicted. The State Supreme Court affirmed the conviction and denied his petition for a writ of habeas corpus, rejecting his contention that the evidence was insufficient to support a finding of guilt beyond reasonable doubt. On federal habeas, the District Court also rejected that contention. The Fourth Circuit Court of Appeals reversed the District Court's decision on the ground that the standard set in Jackson v. Virginia, making evidence sufficient to support a conviction as a matter of due process if, "after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt," had not been met.

The United States Supreme Court granted certiorari to review the case.

B. Counsel of Record:
ACLU Side
(Respondent/Appellee)
Opposing Side
(Petitioner/Appellant)
Steven H. Goldblatt argued the cause and filed a brief for respondent.
Donald R. Curry, Senior Assistant Attorney General of Virginia, argued the cause for petitioners. With him on the briefs were Mary Sue Terry, Attorney General; H. Lane Kneedler, Chief Deputy Attorney General; Stephen D. Rosenthal, Deputy Attorney General; and Jerry P. Slonaker, Senior Assistant Attorney General.
C. The Arguments:
ACLU Side
(Respondent/Appellee)
Opposing Side
(Petitioner/Appelant)
Unavailable Unavailable
III. AMICI CURIAE:
ACLU Side
(Respondent/Appellee)
Opposing Side
(Petitioner/Appelant)
Leslie A. Harris, Steven R. Shapiro, and John A. Powell filed a brief for the American Civil Liberties Union, et al., as amici curiae urging affirmance.

Additional briefs urging affirmance were filed for the State of New York, et al., by Robert Abrams, Attorney General of New York; Lee Fisher, Attorney General of Ohio; Jerry Boone, Solicitor General of New York; Peter H. Schiff, Deputy Solicitor General; and Martin A. Hotvet, Assistant Attorney General; for Senator Biden, et al., by William F. Sheehan and Christopher E. Palmer; for the American Bar Association by Talbot D’Alemberte and Seth P. Waxman; for Benjamin R. Civiletti, et al., by Douglas G. Robinson and James S. Liebman; and for Gerald Gunther, et al., by Larry W. Yackle.

Maureen E. Mahoney, Deputy Solicitor General, argued the cause for the United States as amicus curiae urging reversal. On the brief were Solicitor General Starr, Assistant Attorney General Mueller, and Deputy Solicitor General Roberts.

Briefs of amici curiae urging reversal were filed for the State of Florida et al. by Robert A. Butterworth, Attorney General, and Richard B. Martell, Assistant Attorney General; Charles E. Cole, Attorney General of Alaska; Grant Woods, Attorney General of Arizona; Winston Bryant, Attorney General of Arkansas; Daniel E. Lungren, Attorney General of California; Gale A. Norton, Attorney General of Colorado; Richard N. Palmer, Chief State’s Attorney of Connecticut; Charles M. Oberly III, Attorney General of Delaware; Michael J. Bowers, Attorney General of Georgia; Warren Price III, Attorney General of Hawaii; Larry EchoHawk, Attorney General of Idaho; Linley E. Pearson, Attorney General of Indiana; Bonnie J. Campbell, Attorney General of Iowa; Robert T. Stephen, Attorney General of Kansas; Chris Gorman, Attorney General of Kentucky; Joseph Curran, Jr., Attorney General of Maryland; Hubert H. Humphrey III, Attorney General of Minnesota; Michael C. Moore, Attorney General of Mississippi; William L. Webster, Attorney General of Missouri; Marc Racicot, Attorney General of Montana; Don Stenberg, Attorney General of Nebraska; Frankie Sue Del Papa, Attorney General of Nevada; John P. Arnold, Attorney General of New Hampshire; Robert J. Del Tufo, Attorney General of New Jersey; Tom Udall, Attorney General of New Mexico;  Lacy H. Thornburg, Attorney General of North Carolina; Nicholas J. Spaeth, Attorney General of North Dakota; Susan B. Loving, Attorney General of Oklahoma; Charles S. Crookham, Attorney General of Oregon; Ernest D. Preate, Jr., Attorney General of Pennsylvania; Travis Medlock, Attorney General of South Carolina; Mark Barnett, Attorney General of South Dakota; Dan Morales, Attorney General of Texas; Paul Van Dam, Attorney General of Utah; Jeffrey L. Amestoy, Attorney General of Vermont; Kenneth O. Eikenberry, Attorney General of Washington; Mario J. Palumbo, Attorney General of West Virginia; and Joseph B. Meyer, Attorney General of Wyoming; and for the Criminal Justice Legal Foundation by Kent S. Scheidegger.
 IV. THE SUPREME COURT'S DECISION:

"The case against West was strong… [O]ver 15 of the items stolen were recovered from West’s home. On direct examination at trial, West said nothing more than that he frequently bought and sold items at different flea markets. He failed to offer specific information about how he had come to acquire any of the stolen items...

As the trier of fact, the jury was entitled to disbelieve West’s uncorroborated and confused testimony. In evaluating that testimony, moreover, the jury was entitled to discount West’s credibility on account of his prior felony conviction...

We think it clear that the trial record contained sufficient evidence to support West’s conviction...

[Jackson v. Virginia] required the federal courts to deny the requested writ of habeas corpus if, under the Jackson standard, there was sufficient evidence to support West’s conviction, which, as the principal opinion amply demonstrates… there certainly was...

The judgment of the Court of Appeals is reversed, and the case is remanded for further proceedings consistent with this opinion."

Justice Vote: 0 Pro vs. 9 Con

  • Thomas, C.  Con (Wrote majority opinion)
  • Souter, D.  Con (Wrote concurring opinion)
  • Kennedy, A.  Con (Wrote concurring opinion)
  • Scalia, A.  Con (Joined majority opinion)
  • Rehnquist, W.  Con (Joined majority opinion)
  • White, B.  Con (Wrote concurring opinion)
  • O’Connor, S.  Con (Wrote concurring opinion)
  • Blackmun, H.  Con (Joined O’Connor’s concurring opinion)
  • Stevens, J.  Con (Joined O’Connor’s concurring opinion)
V. A WIN OR LOSS FOR THE ACLU?

The ACLU filed a brief as amicus curiae urging affirmance;  the Supreme Court reversed the ruling of the Court of Appeals for the Fourth Circuit in a 9-0 vote, giving the ACLU an apparent loss.