Jackson v. Virginia, 443 U.S. 307 (1979)

In this case the Supreme Court held that due process mandates reversal of a conviction if, viewing the evidence in the light most favorable to the prosecution, no rational fact finder could have found the defendant guilty beyond a reasonable doubt.

In state court, Jackson was found guilty of firstdegree murder, although he presented evidence that he acted in self-defense, or alternatively, was too intoxicated to form the specific intent necessary for firstdegree murder.

After failing in his state appeal, Jackson filed a federal habeas corpus petition on the ground of insufficiency of the evidence to support the conviction. The lower federal courts denied the petition using a ‘‘no evidence’’ test, under which a defendant could gain a reversal only if there was a complete lack of evidence to support an element of the offense. The Supreme Court concluded, five to three, that because under In re Winship (1968) the prosecution is required to prove every element beyond a reasonable doubt, reversal is required if no rational fact finder could have found guilt beyond a reasonable doubt. However, under this standard, the Court upheld Jackson’s conviction.

As a practical matter, although Jackson may induce more appellants to include an insufficiency claim, it is unlikely that it has produced significantly more reversals, which were rare under the ‘‘no evidence’’ standard and continue to be so. There is almost always some evidence to support a guilty verdict; and viewing that evidence in the light most favorable to the prosecution, an appellate court almost always concludes that it was rational for a fact finder to have found guilt beyond a reasonable doubt.

DAVID MCCORD

Cases and Statutes Cited

• In re Winship, 397 U.S. 358 (1968)

See also Proof beyond a Reasonable Doubt