|Court: U.S. Supreme CourtDocket: 13-946||Opinion Date: October 6, 2014|
|Areas of Law: Civil Rights, Constitutional Law, Criminal Law|
In 2005, Smith’s wife was killed at home by a blow to the head from a log roller. The home appeared to have been ransacked. Jewelry was missing. Smith was charged with first-degree murder. The prosecution presented evidence that he was unfaithful for many years, that his wife was threatening a divorce, and that he told an employee that “the ‘only way’ … out of their marriage was ‘to die’.” Smith’s DNA was found on the murder weapon, duct tape found near the body, and a matchstick that may have been used to burn the body. The missing jewelry was discovered in the trunk of Smith’s car, wrapped in duct tape from the same roll as pieces found near the body. Smith claimed that he could not have delivered the fatal blow due to surgery weeks before the murder. The prosecution successfully requested an aiding-and-abetting instruction and argued that even if he had not delivered the fatal blow, he could be convicted. The jury did not specify which theory it adopted. The California Court of Appeal affirmed, rejecting an assertion that Smith had inadequate notice of the aiding-and-abetting theory. The California Supreme Court denied his petition for review. The Ninth Circuit affirmed the district court’s grant of habeas relief, stating that the information charging first degree murder was initially sufficient, because under California law, aiding and abetting is the same substantive offense as perpetrating the crime, but that Smith’s Sixth Amendment and due process right to notice were violated because the prosecution (until it sought an aiding-and-abetting instruction) had tried the case on the theory that Smith himself had delivered the fatal blow. The Supreme Court reversed. When a state prisoner seeks federal habeas relief on the ground that a state court, in adjudicating a claim on the merits, misapplied federal law, a federal court may grant relief only if the state court’s decision was “contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States,” 28 U. S. C. 2254(d)(1). The Ninth Circuit relied only on its own precedent in this case.
This case is important for several reasons.
1. It holds the prosecution to a higher standard in not allowing them to give a jury instruction that differs from the theory of the case they present at trial. This helps defendant’s because the jury is able to follow one theory, in this case, that Smith aided and abetted in his wife’s murder; not an optional theory that they have to ponder, that he committed the actual murder by delivering the fatal blow, which is the theory the prosecution sought to prove throughout the trial. Only when the prosecution decided to add the limiting jury instruction that differed from their original theory, did they seek to tell the jury subconsciously “if you cannot find him guilty of committing the actual crime, find him guilty of aiding in abetting” under CA law, it is just as good as committing the crime.
2. It helps the jurors make a sound decision on the theory presented. It does not offer them the added opportunity to consider other possible options.
3. Makes it more difficult for the prosecution to prove their case.
What do I hope will happen in light of this new case law? I hope that more people will have their convictions overturned because the prosecution violated their Due Process Rights.