McDaniel v. Brown (2009)
- Docket
- 08-559
- Decided
- 2009-01-01
Summary
Question: Did the U.S. Court of Appeals, Ninth Circuit, properly apply the Jackson analysis in determining whether or not Brown's conviction was rational? May the district court consider the Mueller report as part of a Jackson analysis? Conclusion: No and no. In a per curiam opinion with two justices concurring, the Court held that the Mueller report could not be considered as part of a Jackson analysis. The Court noted that the respondent no longer argued that it was proper to admit the Mueller report as a supplement. Moreover, the Mueller report did not contest that the DNA matched Troy Brown, although it did suggest that the state's expert overstated the DNA evidence's value. The Court pointed to other evidence placing Troy Brown's brothers away from the scene of the crime, and argued that the jury could have rationally inferred from the evidence that Troy was at the scene of the crime at the time of the assault. It reasoned that the Ninth Circuit failed to take this circumstantial evidence into account. The Court declined to decide whether or not the DNA evidence was improperly admitted under federal law because the respondent did not properly raise the question. Justice Clarence Thomas, joined by Justice Antonin Scalia, concurred. He wrote that the Ninth Circuit's judgment was incorrect because it took into consideration evidence that was not admitted at trial. According to Justice Thomas, this was sufficient to show that the Ninth Circuit's Jackson analysis was not proper.