U.S. Supreme Court
Pilon v. Bordenkircher, 444 U.S. 1 (1979)
Pilon v. Bordenkircher
Decided October 9, 1979
444 U.S. 1
Held: The requirement under the Due Process Clause of the Fourteenth Amendment that a criminal conviction be based upon proof of guilt beyond a reasonable doubt can be effectuated only if a federal habeas corpus court, in assessing the sufficiency of the evidence to support a state court conviction, inquires
"whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt."
Jackson v. Virginia, 443 U. S. 307, 443 U. S. 319. Thus, in the instant case, the District Court and the Court of Appeals which, prior to the decision in Jackson v. Virginia, supra, had denied habeas corpus relief to petitioner from his state court conviction, erred in applying the "no evidence" test that was held to be constitutionally inadequate in Jackson, and the case will be remanded to the District Court for reconsideration in the light of Jackson.
Certiorari granted; 593 F.2d 26, vacated and remanded.