MCDANIEL v. BROWN

Troy Brown was convicted in a Nevada state court on two counts of sexual assault on a child and one count of abuse or neglect of a child. He was subsequently denied post-conviction relief by the Nevada Supreme Court.

In 2004, Mr. Brown filed a petition for habeas corpus relief in the federal district court of Nevada arguing that DNA evidence was improperly admitted at his trial, thus violating his Fourteenth Amendment Due Process rights. The federal district court agreed and granted his petition. On appeal, the U.S. Court of Appeals for the Ninth Circuit affirmed. It held that Mr. Brown's Due Process rights were violated when DNA evidence was improperly admitted at trial and that in its absence "no rational trier of fact" could have found "beyond a reasonable doubt" that he committed the crime with which he was charged. The court noted that the Nevada Supreme Court erred in applying a "reasonable trier of fact" standard as opposed to the more appropriate "rational trier of fact" standard as illustrated by the Supreme Court in Jackson v. Virginia when reviewing Mr. Brown's case.