RESPONDENT: Marvin Vernis Smith
LOCATION: Superior Court of Orange County
DOCKET NO.: 13-946
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Ninth Circuit
CITATION: 574 US (2014)
GRANTED: Oct 06, 2014
DECIDED: Oct 06, 2014
Facts of the case
On December 15, 2005, Minnie Smith was found dead in the home she shared with her husband, Marvin Smith. Smith was charged with first-degree murder for the death of his wife. At the end of the trial, the prosecution asked for and received an aiding-and-abetting instruction, which would allow the jury to convict Smith even if they found that he had not delivered the fatal blow. The jury convicted Smith but did not specify which theory of guilt they adopted. The California Court of Appeal affirmed the conviction and rejected Smith's argument that he had not been given adequate notice of the possibility of the aiding-and-abetting instruction. The California Supreme Court denied Smith's petition for review.
Smith filed a petition for habeas relief. The Magistrate Judge recommended granting the relief, and the district court agreed. The U.S. Court of Appeals for the Ninth Circuit affirmed and held that Smith should have been aware that the aiding-and-abetting instruction was possible because under California law aiding and abetting the crime is part of the same substantive offense as the commission of the crime itself. However, the appellate court held that Smith's Sixth Amendment right had been violated because the prosecution had tried the case on a single theory before adding the second instruction at the very end of the trial. In reaching this decision, the appellate court relied on its own precedent, which it claimed faithfully applied Supreme Court precedent.
Did the U.S. Court of Appeals for the Ninth Circuit properly apply its own precedent in determining that Smith's habeas petition should be granted?