Rodriguez v. Rozum

The Facts

The petitioner, Rodriguez, was involved in marijuana sale in organized group. Once during the narcotics transaction accomplices began shooting other parties. After the shooting, Rodriguez drove head of the gang, Macho, away from place of crime somewhere named Whitaker Avenue. Their friend arrived soon thereafter, and drove Rodriguez and other accomplice to Rodriguez’s home. Rodriguez kept the drugs, while his Macho kept both the gun and the money.

Procedural History

The appellate court reversed the judgment of the district court, and remanded the issue.


When a habeas petitioner alleges entitlement to habeas relief the federal courts must apply a “twice-deferential standard” of review. Under the first layer of the standard, the evidence is sufficient to support a conviction when rational trier of fact reveals the essential elements of the crime beyond a reasonable doubt. But each factual evidence ought to be evaluated in the way the most favorable to prosecution even if  records support conflicting inferences the court is expected to  presume. The second layer of the standard assumes that the federal court can reverse the state-court conviction only if the decision was objectively unreasonable. When state court’s findings of fact are objectively unreasonable, a decision adjudicated on the merits and based on a factual determination must be overturned on factual grounds. The court determines reasonableness based on the record evidence at the time of the state court adjudication.

The Issue

Whether district court’s grant of petition for a writ of habeas corpus was justified.

The Holding/Reasoning

The US Court of Appeals held that district court erred in finding insufficient evidence to support the conviction, as there was sufficient evidence to establish accomplice liability. Hence, the Court admitted that “the inmate was an active participant in the robbery, and he and the shooter fled in concert. The inmate’s post-offense conduct provided circumstantial evidence of criminal intent”. According to the appellate court there was sufficient evidence to establish factual circumstances that defendant acted with the intent of promoting or facilitating the commission of the robbery as required by 18 Pa. Const. Stat. § 306(c).

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