WADDINGTON v. SARAUSAD

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Case Basics
Docket No. 
07-772
Petitioner 
Doug Waddington, Superintendent, Washington Corrections Center
Respondent 
Cesar Sarausad
Advocates
(argued the cause for the petitioner)
(argued the cause for the respondent)
Term:
Facts of the Case 

Cesar Sarausad was arrested in Washington state for his involvement in a drive-by shooting near a school. After he was convicted of second-degree murder and two attempted second-degree murder charges in a jury trial, Sarausad filed a petition for habeas corpus in the U.S. District Court for the Western District of Washington. The district court granted Sarausad's motion, holding that the evidence was insufficient to support the conviction and that certain confusing jury instructions related to accomplice liability unconstitutionally relieved the state of its burden of proof.

On appeal, the U.S. Court of Appeals for the Ninth Circuit reversed the district court's ruling on the insufficiency of evidence claim but affirmed on the jury instructions claim. The court stated that the evidence at trial was sufficient to support a conviction under Jackson v. Virginia. However, the jury instructions were ambiguous on the question of whether Sarausad could be convicted of murder and attempted murder on a theory of accomplice liability without proof beyond a reasonable doubt that he knew an accomplice intended to commit a murder. According to the Ninth Circuit, there was a reasonable chance the jury misapplied these instructions.

Question 

1) In reviewing a due process challenge to a jury instruction, must federal courts accept state court findings that instructions were correct?

2) Did the U.S. Court of Appeals err in affirming federal habeas corpus relief when it found a "reasonable likelihood" that the jury misapplied the jury instruction in Mr. Sarausad's case and thereby relieved the state of its burden to prove every element of the crime beyond a reasonable doubt?

Conclusion 
Decision: 6 votes for Waddington, 3 vote(s) against
Legal provision: Due Process

Not necessarily and yes. In a 6-3 decision with Justice Clarence Thomas writing for the majority and joined by Chief Justice John G. Roberts, Justice Antonin G. Scalia, Justice Anthony M. Kennedy, Justice Stephen G. Breyer, and Justice Samuel A. Alito, the Supreme Court reversed the U.S. Court of Appeals for the Ninth Circuit. The Court held that a federal court may reject state court conclusions with respect to the appropriateness of a state court jury instruction, so long as the instructions were "not only erroneous, but objectively unreasonable." Here, the standard was not met and the Ninth Circuit should have accepted the conclusions of the state courts. Further, the Court held that the Ninth Circuit erred in finding Mr. Sarausad's jury instructions so ambiguous that his constitutional rights were violated and therefore he was not entitled to federal habeas corpus relief.

Justice David H. Souter dissented and was joined by Justice John Paul Stevens and Justice Ruth Bader Ginsburg. Justice Souter criticized the majority opinion for relying on the fact that the jury instructions in Mr. Sarausad's case incorporated part of a state statute as evidence enough that the instructions were unambiguous. Further, he noted that the jury asked three times for clarification in the instructions. Therefore, Justice Souter argued, it was likely the jury did not grasp what it needed to find in order to convict Mr. Sarausad for accomplice liability.

Cite this Page
WADDINGTON v. SARAUSAD. The Oyez Project at IIT Chicago-Kent College of Law. 11 September 2014. <http://www.oyez.org/cases/2000-2009/2008/2008_07_772>.
WADDINGTON v. SARAUSAD, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2000-2009/2008/2008_07_772 (last visited September 11, 2014).
"WADDINGTON v. SARAUSAD," The Oyez Project at IIT Chicago-Kent College of Law, accessed September 11, 2014, http://www.oyez.org/cases/2000-2009/2008/2008_07_772.