## Facts

- A 7-week-old infant, Etzel Glass, died after being found limp and unresponsive while under the care of his grandmother, Shirley Ree Smith, who was sleeping nearby.
- Smith reported believing the baby had fallen from a sofa; emergency responders found no breathing and no heartbeat.
- Doctors initially considered sudden infant death syndrome, but an autopsy led the coroner to conclude the death resulted from shaken baby syndrome.
- After learning of the autopsy conclusion, Smith told a social worker she had picked up the baby and given him “a little shake, a jostle” to wake him, and then expressed concern that she may have caused the harm.
- At trial for assault on a child resulting in death under California law, the prosecution presented three medical experts supporting shaken baby syndrome/brainstem trauma as the cause of death.
- The defense presented two experts who disputed shaken baby syndrome and opined that the death was attributable to other trauma or sudden infant death syndrome.
- After extensive expert testimony, the jury convicted Smith; state courts upheld the conviction on direct review.

## Issues

1. Whether, under Jackson v. Virginia, the evidence was constitutionally insufficient to support the conviction.
2. Whether AEDPA permitted a federal habeas court to grant relief by reweighing conflicting expert testimony and rejecting the state courts’ determination that the evidence was sufficient.

## Decision

- The Supreme Court reversed the Ninth Circuit’s grant of habeas relief in an unsigned per curiam opinion.
- The Court held that the Ninth Circuit improperly substituted its judgment for the jury’s by choosing between competing expert accounts of the infant’s cause of death.
- The Court concluded that, given the expert evidence supporting the prosecution’s theory and the state courts’ rulings, the state-court rejection of the sufficiency challenge was not objectively unreasonable under AEDPA.

## Legal Principles

- Under Jackson v. Virginia, a reviewing court may overturn a conviction for insufficient evidence only if no rational trier of fact could have found guilt beyond a reasonable doubt.
- Credibility determinations and resolution of conflicting testimony, including expert disputes, are primarily for the jury rather than a reviewing court.
- On federal habeas review, AEDPA adds a further constraint: a federal court may not overturn a state-court sufficiency ruling merely because it disagrees; relief is available only if the state-court decision is objectively unreasonable.
- The combined Jackson and AEDPA standards impose a demanding, “double deference” framework: deference to the jury’s verdict and deference to the state courts’ adjudication.

## Conclusion

The Court held that federal habeas courts must apply Jackson’s highly deferential sufficiency standard through AEDPA’s additional requirement of deference to reasonable state-court decisions, and may not grant relief by reweighing contested expert testimony when a rational juror could credit the prosecution’s proof.


Cavazos v. Smith, 565 U.S. 1 (2011)