Law School Case Brief
Jackson v. Virginia - 443 U.S. 307, 99 S. Ct. 2781 (1979)
Under Virginia law, murder is defined as the unlawful killing of another with malice aforethought. Premeditation, or specific intent to kill, distinguishes murder in the first from murder in the second degree. Proof of this element is essential to conviction of the former offense, and the burden of proving it clearly rests with the prosecution.
Petitioner Jackson was convicted of first-degree murder after a bench trial in the Virginia circuit court. At trial, Jackson did not dispute that he had in fact shot and killed the victim, but rather argued that he had been too intoxicated at the time to form the specific intent necessary to sustain a conviction of murder in the first-degree. Following his conviction, Jackson filed a petition for habeas corpus in federal district court. The district court granted Jackson's petition, finding that the record contained no evidence of premeditation, and as premeditation was a necessary element of first-degree murder in Virginia, Jackson's conviction unconstitutional. On the Government's appeal, the court of appeals reversed, holding that there was some evidence that Jackson had intended to kill the victim. Jackson was granted a writ of certiorari.
Was Jackson entitled to habeas corpus relief?
The Supreme Court of the United States affirmed the appellate court's judgment. The Court noted that, assuming the procedural prerequisites were satisfied, Jackson was entitled to habeas relief if there was evidence that no rational trier of fact could have found proof of guilt beyond a reasonable doubt. However, the Court ruled, viewed in the light most favorable to the prosecution, sufficient evidence existed for a rational factfinder to conclude beyond a reasonable doubt that Jackson possessed the necessary intent and committed first-degree murder under the law of Virginia, notwithstanding evidence that he had been intoxicated on the day of the killing, since, among other things: (1) uncontradicted evidence established that he shot the victim twice, and; (2) Jackson admitted that the fatal shooting occurred only after he had first fired several shots into the ground and then reloaded his gun.
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