Bennett v. Superintendent Graterford SCI

.In 1990, 19-year-old Bennett was sitting in the passenger seat of a getaway car when his conspirator entered a jewelry store to commit a robbery, shooting the clerk and killing her. Bennett was convicted of first-degree murder. After a capital sentencing hearing, the jury returned a sentence of life imprisonment without the possibility of parole. Two state courts later vacated Bennett’s first-degree murder conviction, finding that the trial court erroneously instructed the jury that it could convict Bennett of first-degree murder based on the shooter’s intent to kill. The Pennsylvania Supreme Court reversed, reinstating the conviction. The Third Circuit granted Bennett’s federal habeas corpus petition, finding that the trial court’s erroneous jury instructions deprived him of due process of law. The court analyzed the issue de novo, concluding that Bennett’s due process claim was not adjudicated on the merits in state court. Due process is violated when a jury instruction relieves the government of its burden of proving every element beyond a reasonable doubt. There is “‘a reasonable likelihood’ that the jury at Bennett’s trial applied the instructions in a way that relieved the state of its burden of proving the specific intent to kill. View "Bennett v. Superintendent Graterford SCI" on Justia Law