Mario Iglesias-Villegas v. United States
DueProcess
1. The Court has held that the due process clause requires the government to prove each element of a criminal offense beyond a reasonable doubt. In re Winship, 397 U.S. 358 (1970). In Jackson v. Virginia, 443 U.S. 307 (1979), the Court ruled that a federal habeas court reviewing a challenge to the sufficiency of the evidence supporting a state conviction had to apply the reasonable-doubt standard to determine whether a reasonable factfinder could have found every element of the charged offense had been proved by the government. Winship and Jackson appear to set a clear constitutional minimum for obtaining and sustaining a conviction ‒the evidence must prove every element of the charged offense beyond a reasonable doubt. Nonetheless, the Fifth Circuit applies a lesser standard when a defendant does not make or renew a motion for acquittal under Federal Rule of Appellate Procedure 29 at the close of all the evidence. Rather than look for proof of every element, the Fifth Circuit reviews only to see if the record is devoid of evidence of guilt.
The question presented is whether a federal court of appeals reviewing a defendant's direct-appeal challenge to the sufficiency of the evidence supporting his conviction must apply the every-element, reasonable-doubt standard articulated in Jackson v. Virginia.
2. Whether an accused has made a sufficient showing of the need for grand jury transcripts under Federal Rule of Criminal Procedure 6(e)(3)(E) when he demonstrates that the government had, at the time it obtained the indictment against him, confused him with another person and had apparently treated that other person's acts as the defendant's acts.
Whether a federal court of appeals reviewing a defendant's direct-appeal challenge to the sufficiency of the evidence supporting his conviction must apply the every-element, reasonable-doubt standard articulated in Jackson v. Virginia