Waddington v. Sarausad

Facts of the Case

Respondent Cesar Sarausad drove the car in a driveby shooting at a high school, which was the culmination of a gang dispute. En route to school, Ronquillo, the front seat passenger, covered his lower face and readied a handgun. Sarausad slowed down upon reaching the school, Ronquillo fired at a group of students, killing one and wounding another, and Sarausad then sped away. He, Ronquillo, and Reyes, another passenger, were tried on murder and related charges. Sarausad and Reyes, who were tried as accomplices, argued that they were not accomplices to murder because they had not known Ronquillo’s plan and had expected at most another fistfight. In her closing argument, the prosecutor stressed Sarausad’s knowledge of a shooting, noting how he drove at the scene, that he knew that fighting alone would not regain respect for his gang, and that he was in for a dime, in for a dollar. The jury received two instructions that directly quoted Washington’s accomplice-liability law. When the jury failed to reach a verdict as to Reyes, the judge declared a mistrial as to him. The jury then convicted Ronquillo on all counts and convicted Sarausad of second-degree murder and related crimes.

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?

CONCLUSION

Not necessarily and yes. In a 6-3 decision with Justice Clarence Thomas writing for the majority and joined by Chief Justice John G. Roberts, Justice Antonin G. Scalia, Justice Anthony M. Kennedy, Justice Stephen G. Breyer, and Justice Samuel A. Alito, the Supreme Court reversed the U.S. Court of Appeals for the Ninth Circuit. The Court held that a federal court may reject state court conclusions with respect to the appropriateness of a state court jury instruction, so long as the instructions were not only erroneous, but objectively unreasonable. Here, the standard was not met and the Ninth Circuit should have accepted the conclusions of the state courts. Further, the Court held that the Ninth Circuit erred in finding Mr. Sarausad’s jury instructions so ambiguous that his constitutional rights were violated and therefore he was not entitled to federal habeas corpus relief.Justice David H. Souter dissented and was joined by Justice John Paul Stevens and Justice Ruth Bader Ginsburg. Justice Souter criticized the majority opinion for relying on the fact that the jury instructions in Mr. Sarausad’s case incorporated part of a state statute as evidence enough that the instructions were unambiguous. Further, he noted that the jury asked three times for clarification in the instructions. Therefore, Justice Souter argued, it was likely the jury did not grasp what it needed to find in order to convict Mr. Sarausad for accomplice liability.

Case Information

  • Citation: 555 US _ (2009)
  • Granted: Mar 17, 2008
  • Argued: Oct 15, 2008
  • Decided Jan 21, 2009