U.S. Supreme Court
Moore v. Duckworth, 443 U.S. 713 (1979)
Moore v. Duckworth
Decided July 2, 1979
443 U.S. 713
Petitioner, who, upon a plea of not guilty by reason of insanity, was found guilty of second-degree murder by an Indiana jury, sought federal habeas corpus relief after the Indiana Supreme Court affirmed the conviction, claiming, inter alia, that he had been denied due process because he had been convicted upon evidence insufficient to prove beyond a reasonable doubt that he was sane at the time of the killing. The District Court denied the writ, and the Court of Appeals affirmed, holding that a challenge to the sufficiency of the evidence presents a federal due process issue "only where a state court conviction is totally devoid of evidentiary support."
Held: Although a state prisoner is entitled to a determination whether the record evidence could support a finding of guilt beyond a reasonable doubt, Jackson v. Virginia, ante, p. 307, nevertheless a remand for further consideration in light of Jackson is inappropriate here. The Court of Appeals properly deferred to a rule of Indiana law permitting sanity to be established by either expert or lay testimony, and although that court applied an improper legal standard in considering the due process claim, it appears that such claim concerned the above Indiana rule, and that the evidence in support of the conviction was constitutionally adequate under the Jackson standard.
Certiorari granted; 581 F. d 639, affirmed.