In Cavazos v. Smith, No. 10-1115, October 31, 2011, the defendant was convicted for her role in the death of her 7-week old son and sentenced to fifteen years in prison. The prosecution’s three experts testified that the death of the child was the result of shaken baby syndrome (SBS). One defense expert testified that the child died from old brain trauma and another defense expert testified that the child’s death was due to sudden infant death syndrome (SIDS).
In seeking habeas relief, the defendant argued that the evidence was insufficient to prove that the child died of SBS. The United States Supreme Court overturned the Ninth Federal Circuit Court of Appeals holding that the Ninth erred in granting the defendant’s habeas petition because the evidence presented at trial supported the jury’s decision since. The Court specifically cited expert opinion that the child died from severe shaking that caused a tear in the child’s brain stem. The federal appellate court improperly substituted its judgment for that of the jury on the question whether the prosecution’s expert or the defense’s expert more persuasively explained the cause of death.
The USSC held that t is the responsibility of a jury, not a court, to decide what conclusions should be drawn from evidence admitted at trial. A reviewing court may set aside the jury’s verdict on the ground of insufficient evidence only if no rational trier of fact could have agreed with the jury. Further, a federal court may not overturn a state court decision rejecting a sufficiency of the evidence challenge simply because the federal court disagrees with the state court. The federal court instead may do so only if the state court decision was objectively unreasonable. (Per curiam opinion, Roberts, Scalia, Kennedy, Thomas, Alito, and Kagan)
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The United States Supreme Court ruled definitively on June 16, 2011 that prisons are for punishment, not for rehabilitation. In Tapia v. United States, Petitioner was convicted by a federal district court of smuggling unauthorized aliens into the United States and was sentenced to 51 months imprisonment so the petitioner could participate in the U.S. Bureau of Prison's Residential Drug Abuse Program. Petitioner appealed, claiming that the district court violated 18 U.S.C. 3582(a) when it imposed sentence substantially influenced the opportunity to participate in the rehabilitation program. The U.S. Court of Appeals for the Ninth Circuit upheld petitioner's conviction and sentence, and the U.S. Supreme Court granted certiorari.
In a unanimous holding, the United States Supreme Court reversed the Ninth Circuit Court holding that 18 U.S.C. 3582(a) precludes sentencing courts from imposing or lengthening a prison term to promote an offender's rehabilitation. 18 U.S.C. 3582(a) specifies the factors to be considered when a court orders imprisonment, if imprisonment is to be imposed at all, including the length of the term of incarceration. The Court substantiated the legislature’s position that imprisonment is not an appropriate means of promoting correction and rehabilitation. The U.S. Sentencing Commission, the author of the U.S. Sentencing Guidelines, notes the impropriety of imposing a term of imprisonment for the purpose of rehabilitating a defendant or providing a defendant with substance abuse treatment, educational or vocational training, medical care, or other correctional intervention. Specifically, a court making these sentencing determinations should consider the specified rationales of punishment described in 18 U.S.C. 3582(a) except for rehabilitation, i.e. it is inappropriate to imposing a prison sentence for the purpose of rehabilitating a defendant or providing a defendant with educational or vocational training, medical care, or other correctional treatment. In short, courts are not to use prison as a way to rehabilitate an offender. The Court rationalizes that if Congress had meant to allow courts to base prison terms on offenders' rehabilitative needs, it would have given courts the capacity to ensure that offenders participate in prison correctional programs. But in fact, courts do not have this authority.