Deanna Brookhart, Warden v. Kenneth Smith

Respondent Kenneth Smith has been tried and convicted on three separate occasions for Raul Briseno’s murder. During the last two trials, the jury heard and rejected evidence that another group of people committed the murder. On appeal from the jury’s most recent verdict, the Illinois Appellate Court issued an exhaustive 93-page opinion that carefully considered and rejected each of respondent’s asserted errors. But the Seventh Circuit nonetheless granted habeas relief, reasoning that the state appellate court had unreasonably applied Jackson v. Virginia, 443 U.S. 307 (1979), in upholding the jury’s verdict. According to the Seventh Circuit, although it did not intend to “adjudicate the [alternative suspects’] guilt,” the evidence implicating these suspects—evidence the jury heard and rejected—“cast[] a powerful reasonable doubt” on the State’s theory that respondent committed the murder, such that “no rational trier of fact” could have reached the verdict the jury did. App. 30a (emphasis in original). The question presented is whether the Seventh Circuit violated 28 U.S.C. § 2254(d)’s strictures in awarding habeas relief to respondent based on its own reweighing of the evidence rather than deferring to the state court’s contrary view.