Facts
- Mark Owen McGuire, a California state prisoner, was tried for the second-degree murder of his infant daughter, Tori.
- The prosecution introduced medical evidence of prior injuries, including rectal tearing (at least six weeks old) and partially healed rib fractures (about seven weeks old).
- Physicians testified the injuries were consistent with “battered child syndrome,” i.e., repeated and/or serious nonaccidental injuries.
- The trial court admitted the prior-injury evidence and instructed the jury it could consider it for a limited purpose, including inferring guilt of the charged offense if there was a “clear connection” between other offenses and the charged crime.
- There was no direct evidence identifying McGuire as the person who inflicted the prior injuries, and the defense did not claim the death was accidental.
- The jury convicted McGuire of second-degree murder.
Issues
- Whether admitting evidence of prior injuries and battered child syndrome, without proof McGuire inflicted the prior injuries, rendered the trial so arbitrary and fundamentally unfair as to violate due process on federal habeas review.
- Whether the prior-acts instruction created a reasonable likelihood the jury convicted based on propensity or relieved the State of proving the charged offense beyond a reasonable doubt, in violation of due process.
- Whether a federal habeas court may effectively revisit state-law evidentiary determinations by recasting them as federal due process violations.
Decision
- The Supreme Court reversed the Ninth Circuit’s grant of habeas relief.
- The Court held that federal habeas courts may not reexamine state-court determinations on state-law evidentiary questions; relief does not lie for mere state-law error.
- The challenged evidence was relevant to intent because it tended to show the fatal injuries were inflicted intentionally and not by accident, and its admission did not make the trial fundamentally unfair.
- Considering the jury charge as a whole, there was no reasonable likelihood the jury applied the instruction in a constitutionally impermissible way.
- Justice O’Connor (joined by Justice Stevens) agreed the evidence was relevant but would have found the instruction constitutionally erroneous and would have remanded for harmless-error review.
Legal Principles
- Federal habeas relief is available only for violations of the Constitution, laws, or treaties of the United States; it is not a mechanism to correct errors of state law.
- A state evidentiary ruling violates due process only if it so infects the trial with unfairness as to deny due process.
- Evidence of prior injuries consistent with battered child syndrome may be constitutionally admissible to prove intent and to negate accident, even if the defendant is not directly linked to each prior injury, so long as the trial remains fundamentally fair.
- Jury instructions are assessed in context; the question is whether there is a reasonable likelihood the jury applied the instruction in a way that violates the Constitution, and the charge must be read as a whole.
Conclusion
The Supreme Court held that, on federal habeas review, the admission of battered-child-syndrome evidence and a related limiting instruction did not violate due process because they did not render the trial fundamentally unfair, and federal courts may not grant habeas relief for alleged errors of state evidentiary law absent a constitutional violation.