In Jackson v. Virginia, the Burger Court recently made an apparent "about face" with regard to the scope of powers extended to a federal habeas corpus court reviewing a state court conviction. On the basis of this ruling, habeas corpus petitioners may now demand federal court examination of whether the evidence produced at their trials was sufficient to justify a finding of guilt beyond a reasonable doubt. Jackson is, therefore, a significant step beyond the Warren Court rule that due process is violated only when the record is totally devoid of any evidence to support the conviction.
Jennie L. Montgomery,
Federal Habeas Corpus: Greater Protection for "Innocent" State Prisoners After Jackson v. Virginia,
U. Rich. L. Rev.
Available at: http://scholarship.richmond.edu/lawreview/vol14/iss2/7