Cortez J. Jackson v. Rochelle Moore, Warden, Pickaway Correctional Institution

Summary

This Report and Recommendations addresses Cortez J. Jackson’s federal habeas corpus petition challenging his Ohio convictions for felony murder and tampering with evidence. The magistrate judge recommends dismissing the petition with prejudice, finding the manifest-weight claim noncognizable in federal habeas proceedings and the insufficiency-of-the-evidence claim meritless under the deferential Jackson v. Virginia and AEDPA standards.

Holdings

1. A claim that a state conviction is against the manifest weight of the evidence does not present a federal constitutional claim cognizable in habeas corpus.
2. The insufficiency-of-the-evidence claim is cognizable under the Fourteenth Amendment, but the evidence was sufficient for a rational trier of fact to find the elements of felony murder and tampering with evidence beyond a reasonable doubt.
3. The petition should be dismissed with prejudice because the manifest-weight claim is not cognizable and the state court's rejection of the sufficiency claim was reasonable under Jackson v. Virginia and AEDPA.

Questions Presented

1. Whether the manifest-weight-of-the-evidence claim is cognizable in federal habeas corpus.
2. Whether the evidence was constitutionally sufficient under the Fourteenth Amendment to support Jackson's felony-murder and tampering-with-evidence convictions.
3. Whether the Ohio appellate court's rejection of Jackson's sufficiency claim was contrary to, or an unreasonable application of, clearly established federal law or based on an unreasonable determination of the facts under AEDPA.

Disposition

other