Cavazos v. Smith

HABEAS CORPUS (Certiorari granted and the judgment of the Ninth Circuit Court of Appeals in Cavazos v. Smith is reversed)

Shirley Ree Smith was found guilty of assault on a child resulting in death in connection with the death of her seven-week-old grandson, Etzel. Denying Smith’s motion for a new trial, the trial court sentenced her to 15 years to life in prison. Smith challenged her conviction contending that the evidence presented was insufficient to establish that Etzel died from Shaken Baby Syndrome (SBS). The California Court of Appeals rejected her claim and the California Supreme Court denied review. Smith filed a petition for writ of habeas corpus in U.S District Court for the Central District of California. The District Court could not grant relief unless Smith could show either that the California Court of Appeal’s decision affirming the conviction was contrary to, or involved an unreasonable application of, clearly established federal law as reflected in U.S. Supreme Court cases or that it was based on an unreasonable determination of the facts in light of the state court record as required under the Antiterrorism and Effective Death Penalty Act of 1996. The District Court, adopting the Magistrate Judge’s report concluding that the conviction was supported by sufficient evidence, denied Smith’s petition. Smith appealed and the Ninth Circuit reversed with instructions to the District Court to grant the writ.

The Supreme Court held that the Ninth Circuit erred in concluding that the evidence presented at trial did not support the jury’s verdict. The Court determined that the jury’s verdict, which hinged on assessing the credibility of conflicting expert medical testimony, was supported by the evidence presented at trial. The Court reversed the Ninth Circuit decision and remanded the case for further proceedings consistent with its opinion.