Estelle v. McGuire, 502 U.S. 62 (1991)

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certiorari to the united states court of appeals for the ninth circuit

No. 90-1074. Argued October 9, 1991—Decided December 4, 1991

Respondent McGuire was found guilty in a California state court of the second-degree murder of his infant daughter, Tori. Among the prosecution's witnesses were two physicians, who testified that Tori was a battered child who had suffered prior injuries. The battered child testimony revealed evidence of rectal tearing, which was at least six weeks old, and evidence of partially healed rib fractures, which were approximately seven weeks old. The trial court instructed the jury that the prior injury evidence could be considered for "the limited purpose of determining if it tends to show . . . a clear connection between the other two offense[s] and the one of which [McGuire] is accused, so that it may be logically concluded that if the Defendant committed other offenses, he also committed the crime charged in this case." The State Court of Appeal upheld the conviction, finding that the introduction of prior injury evidence was proper under state law to prove "battered child syndrome," which exists when a child has sustained repeated and/or serious injuries by nonaccidental means. Subsequently, the Federal District Court denied McGuire's petition for habeas corpus. The Court of Appeals reversed, concluding that the trial was arbitrary and fundamentally unfair in violation of due process. It ruled that the prior injury evidence was erroneously admitted to establish battered child syndrome, because there was no evidence linking McGuire to the prior injuries and no claim made at trial that Tori died accidently, and that the jury instruction on the use of prior act evidence allowed a finding of guilt based simply on a judgment that he committed the prior acts.

Held: Neither the admission of the challenged evidence nor the jury instruction as to its use rises to the level of a due process violation. Pp. 67-75. (a) The prior injury evidence, although not linked to McGuire himself, was probative on the question of the intent with which the person who caused Tori's injuries acted, since it demonstrated that her death was the result of an intentional act by someone, and not an accident. The fact that no claim that Tori died accidentally was made at trial did not relieve the prosecution of its burden to prove all of the essential elements of second-degree murder beyond a reasonable doubt. By eliminating the possibility of accident, the evidence was clearly probative of

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