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Waddington v. Sarausad

Docket No.: 07-772
Certiorari Granted: Mar 17 2008
Argued: October 15, 2008
Decided: January 21, 2009

PartyNames: Doug Waddington, Superintendent, Washington Corrections Center v. Cesar Sarausad
Petitioner: Doug Waddington, Superintendent, Washington Corrections Center
Respondent: Cesar Sarausad

Court Below: United States Court of Appeals for the Ninth Circuit

Doug Waddington, Superintendent, Washington Corrections Center
v.
Cesar Sarausad
555 U.S. ____ (2009)
Background:

The Washington Supreme Court has repeatedly approved of the pattern accomplice liability jury instructions given in Sarausad's trial, which mirror the statutory language on accomplice liability under state law. The United States Court of Appeals for the Ninth Circuit found a violation of due process based its independent conclusion that the instructions were ambiguous, and that there was a reasonable likelihood a jury could misapply the instructions so as to relieve the prosecution of its burden to prove each element of a crime beyond a reasonable doubt.

Question Presented:

1. In reviewing a due process challenge to jury instructions brought under 28 U.S.C. ยง 2254, must the federal courts accept the state court determination that the instructions fully and correctly set out state law governing accomplice liability? 2. Where the accomplice liability instructions correctly set forth state law, is it an unreasonable application of clearly established federal law to conclude there was no reasonable likelihood that the jury misapplied the instructions so as to relieve the prosecution of the burden of proving all the elements of the crime?

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?

Holding: judgment reversed and remanded
Vote: 6-3
Opinion By:
Read WADDINGTON V. SARAUSAD opinion (PDF)
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