Held: The requirement under the Due Process Clause of
the Fourteenth Amendment that a criminal conviction be based upon
proof of guilt beyond a reasonable doubt can be effectuated only if
a federal habeas corpus court, in assessing the sufficiency of the
evidence to support a state court conviction, inquires
"whether, 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."
Jackson v. Virginia, 443 U. S. 307,
443 U. S. 319.
Thus, in the instant case, the District Court and the Court of
Appeals which, prior to the decision in
Jackson v. Virginia,
supra, had denied habeas corpus relief to petitioner from his
state court conviction, erred in applying the "no evidence" test
that was held to be constitutionally inadequate in
Jackson, and the case will be remanded to the District
Court for reconsideration in the light of Jackson.
Certiorari granted; 593 F.2d 26, vacated and remanded.
PER CURIAM.
The petitioner was convicted in a Kentucky court on a charge of
first-degree manslaughter, and the judgment of conviction was
sustained on direct appeal.
Pilon v. Commonwealth,
Page 444 U. S. 2
544
S.W.2d 228 (Ky.1976). The petitioner then filed a habeas corpus
petition in a Federal District Court, alleging that the Kentucky
conviction was supported by evidence insufficient to afford him due
process of law. The federal court denied relief. Applying the "no
evidence" test of
Thompson v. Louisville, 362 U.
S. 199 (1960), the court concluded that "[a]lthough this
was a close case on the evidence, we believe that the case was not
devoid of an evidentiary basis for petitioner's conviction."
* The Court of
Appeals for the Sixth Circuit, also relying on the "no evidence"
test, affirmed the denial of habeas corpus relief. 593 F.2d
264.
Thereafter, this Court, in
Jackson v. Virginia,
443 U. S. 307
(1979), held that the
Thompson "no evidence" test is
constitutionally inadequate in a case such as this. An earlier
decision had made clear that the Due Process Clause of the
Fourteenth Amendment prohibits the criminal conviction of any
person except upon proof of guilt beyond a reasonable doubt.
In
re Winship, 397 U. S. 358
(1970). The Court in
Jackson held that this constitutional
requirement can be effectuated only if a federal habeas corpus
court, in assessing the sufficiency of the evidence to support a
state court conviction, inquires
"whether, 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."
443 U.S. at
443 U. S. 319
(emphasis omitted).
It is thus beyond dispute that the District Court and Court of
Appeals applied an incorrect and inadequate constitutional test in
resolving the petitioner's due process claim that his state court
conviction rested on insufficient evidence. Although it is quite
possible that the evidence against the petitioner will survive a
challenge under the correct constitutional standard, he is entitled
to have his application for habeas corpus considered under that
standard.
Page 444 U. S. 3
The motion for leave to proceed
in forma pauperis and
the petition for certiorari are granted, the judgment is vacated,
and the case is remanded to the District Court for the Western
District of Kentucky so that it may consider the petitioner's
application for habeas corpus in the light of
Jackson v.
Virginia.
It is so ordered.
* The opinion of the District Court is unreported.
