Otis Chandler v. Thomas Richards 1 and Indiana Attorney General

935 F.2d 915, 1991 WL 115586
CourtCourt of Appeals for the Seventh Circuit
DecidedJuly 1, 1991
Docket90-2826
StatusPublished
Cited by13 cases

This text of 935 F.2d 915 (Otis Chandler v. Thomas Richards 1 and Indiana Attorney General) is published on Counsel Stack Legal Research, covering Court of Appeals for the Seventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Otis Chandler v. Thomas Richards 1 and Indiana Attorney General, 935 F.2d 915, 1991 WL 115586 (7th Cir. 1991).

Opinion

PER CURIAM.

While serving a 50-year murder sentence in Indiana, Otis Chandler escaped from jail. During the time he was not incarcerated a robbery occurred at an outdoor night depository of a South Bend, Indiana bank. Mr. Chandler was charged with that robbery and after a jury trial was found guilty. He was sentenced to 30 years imprisonment. In a direct appeal to the Indiana Supreme Court, Mr. Chandler contended that the prosecution’s evidence against him was insufficient to sustain the jury’s finding of guilt. The court rejected his argument and upheld his conviction. He then filed a 28 U.S.C. § 2254 petition in federal district court seeking a writ of ha-beas corpus based on his allegation that the jury was presented with insufficient evidence to support a finding of guilt. The district court also rejected his argument, concluding that a rational trier of fact could indeed have found him guilty based on the evidence presented to the jury, as summarized by the state supreme court. 2 Mr. Chandler appeals the district court’s conclusion.

I. Facts

On the night of July 31, 1981 a robbery occurred at an outside night depository station of a bank in South Bend, Indiana. The victim, Timothy Coleman, a co-manager of a local Kroger grocery store, was depositing the day’s receipts at the bank. As he was making his deposit, a man ran up from behind, yelled “drop the bag,” and shot Mr. Coleman in the chest. The attacker then fled across the bank parking lot.

Mr. Coleman testified that he saw his attacker for 5 to 10 seconds, and that the attacker was 5-7 feet away from him at the time of the robbery. Mr. Coleman stated that the robber was wearing a grey sweatsuit and did not have any hat or covering over his face. Further, Mr. Coleman testified that the night depository area was covered by a canopy that held lights and that the area was better lit than the surrounding parking lot.

At the hospital, Mr. Coleman described his attacker as a black male, approximately 5'8", with short hair and prominent features. Several days later, the police brought Mr. Coleman eight mug-shots, including one of Mr. Chandler, and asked if any of the pictures depicted his attacker. Mr. Coleman identified the picture of Mr. Chandler as being that of his attacker. Mr. Coleman also identified Mr. Chandler in the courtroom as his assailant. Another witness at the trial, Jerome Kreczmer, an off-duty police officer and security guard at Kroger, had driven Mr. Coleman to the bank and was inside his car, immediately next to Mr. Coleman, at the time of the shooting. He got out of his car and fired two shots toward the attacker. He testi *917 fied that the attacker was a young black male, about 5'9", wearing shorts and a t-shirt, and that he did not see any hat or other face covering on the attacker. He acknowledged that the police report of his initial description included a notation that he stated that the attacker could have been wearing a baseball cap.

A third witness testified that he heard two shots and then saw a young black man, wearing shorts and a t-shirt, running out of a nearby alley. A woman’s stocking, cut off and tied at one end, was found in the parking lot along the route of the attacker’s escape, as was a baseball cap. In addition, a pair of glasses, with two fingerprints, was found near the edge of the parking lot. However, neither of the fingerprints on the glasses matched those of Mr. Chandler.

Mr. Chandler introduced evidence that he had been alone at his cousin’s home at the time of the crime.

II. Analysis

Mr. Chandler presents a two-part argument to advance his contention that there was insufficient evidence to support his conviction. First, Mr. Chandler argues that the district court erred in applying a statutory presumption of correctness, see 28 U.S.C. § 2254(d) 3 , to the state supreme court’s findings of fact. Mr. Chandler contends that state findings of fact should not be afforded a § 2254(d) presumption by federal courts ruling on habeas petitions based on insufficient evidence. He asserts to do so would eviscerate the review mandated by Jackson v. Virginia, 443 U.S. 307, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979), to ensure the constitutional guarantee that a defendant be convicted only by evidence proving guilt beyond a reasonable doubt. Furthermore, Mr. Chandler contends that applying the standard of Jackson v. Virginia no rational trier of fact could have found Mr. Chandler guilty based on the evidence presented at trial.

Throughout Jackson the Supreme Court stressed the importance of the state fact-finder’s role: “... whether, after reviewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” Id. at 319, 99 S.Ct. at 2789. Jackson highlighted the deference that must be given to the state factfinder’s determinations. The opinion does not mention or address the statutory deference of § 2254(d). This omission however does not mean that § 2254(d) is inapplicable to Jackson reviews. 4 Instead, the deference previously codified in § 2254(d) comports with the Jackson standard for a federal court’s review of a habeas petition challenging the sufficiency of the evidence in a state conviction.

We have commented upon the apparently expanded scope of review available under Jackson, see, Nichols v. Gagnon, 710 F.2d 1267, 1271 (7th Cir.1983). Nevertheless, as a general matter, Jackson follows the basic legal standard that in order to preserve the state factfinder’s role a federal court must review the evidence in light most favorable to the prosecution. Section 2254(d), on the other hand, provides guidance as to the extent a federal court should probe a state court’s factfinding when ruling on habeas petitions. As such, we have consistently conducted Jackson reviews under the guidelines of § 2254(d). See, e.g., Davis v. Franzen, 671 F.2d 1056, 1057 (7th Cir.1982); United States ex rel. Jones v. Franzen, 676 F.2d 261, 265 (7th Cir.1982); Williams v. Duckworth, 738 F.2d 828, 829 n. 2 (7th Cir.1984); Montgomery v. Petersen, 846 F.2d 407, 408 n. 1 (7th Cir.1988).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Griggs v. Fatheree
N.D. Illinois, 2021
Green v. Pollard
E.D. Wisconsin, 2019
Johnson v. Page
971 F. Supp. 350 (N.D. Illinois, 1997)
United States Ex Rel. Williams v. Washington
913 F. Supp. 1156 (N.D. Illinois, 1995)
Wayne K. Lemons v. William D. O'Sullivan
54 F.3d 357 (Seventh Circuit, 1995)
James L. Davis v. Robert A. Farley
23 F.3d 410 (Seventh Circuit, 1994)
Richard Griffiths v. Kenneth McGinnis
23 F.3d 410 (Seventh Circuit, 1994)
William Charles Heck v. Daniel R. McBride
9 F.3d 1549 (Seventh Circuit, 1993)
Michael G. Barger v. State of Indiana
991 F.2d 394 (Seventh Circuit, 1993)
Gilley v. Collins
Fifth Circuit, 1992
Brooke v. Duckworth
824 F. Supp. 839 (N.D. Indiana, 1992)

Cite This Page — Counsel Stack

Bluebook (online)
935 F.2d 915, 1991 WL 115586, Counsel Stack Legal Research, https://law.counselstack.com/opinion/otis-chandler-v-thomas-richards-1-and-indiana-attorney-general-ca7-1991.