SMITH v. WILLIAMS (2021)

United States Court of Appeals, Ninth Circuit.2021-04-01No. No. 19-17514

Summary · law.co

Holding. The district court's judgment denying Smith's habeas corpus petition was affirmed.

Taniko C. Smith, a Nevada state prisoner, sought federal habeas relief under 28 U.S.C. § 2254, challenging an aiding and abetting jury instruction he received at trial. He argued the instruction violated due process by removing the specific intent requirement necessary to prove murder and attempted murder. Applying the deferential standard required by the Antiterrorism and Effective Death Penalty Act, the court found that the instruction adequately conveyed the required mental state to the jury and did not shift the burden of proof away from the state. The instruction therefore did not run afoul of federal constitutional protections against jury instructions that effectively relieve the prosecution of its burden.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Whether an aiding and abetting instruction violated due process by eliminating specific intent element
Whether jury instruction relieved the state of its burden of proof on mental state
Application of AEDPA deference standard to state court decisions

Procedural posture

Smith appealed the district court's denial of his § 2254 habeas corpus petition challenging his state conviction.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

MEMORANDUM **

Nevada state prisoner Taniko C. Smith appeals from the district courts judgment denying his 28 U.S.C. § 2254 habeas corpus petition. We have jurisdiction under 28 U.S.C. § § 1291 and 2253. We review the district courts decision de novo, see Smith v. Ryan, 823 F.3d 1270, 1278 (9th Cir. 2016), and we affirm.

Smith contends that the aiding and abetting instruction given at his trial violated due process because it eliminated the specific intent element required to prove murder and attempted murder. Under the Antiterrorism and Effective Death Penalty Act (AEDPA), we give considerable deference to state court decisions. Habeas relief may only be granted if the adjudication “resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established federal law, as determined by the Supreme Court of the United States” or “resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the state court proceeding.”

28 U.S.C. § 2254(d); see also Harrington v. Richter, 562 U.S. 86, 100, 131 S.Ct. 770, 178 L.Ed.2d 624 (2011). Neither is present in this case. The challenged instruction amply informed the jury of the requisite mental state and did not have “the effect of relieving the State of the burden of proof” on this critical question. See Sandstrom v. Montana, 442 U.S. 510, 521, 99 S.Ct. 2450, 61 L.Ed.2d 39 (1979); see also Waddington v. Sarausad, 555 U.S. 179, 190-92, 129 S.Ct. 823, 172 L.Ed.2d 532 (2009).

AFFIRMED.

FOOTNOTES

. Even if we were to agree with Smith that de novo review applied, his claim would still fail.