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Rape Conviction Should Stand, High Court Rules

(CN) - The Supreme Court ruled Monday that the lower courts "clearly" erred in overturning a man's rape conviction, despite "DNA evidence and other convincing evidence of guilt."

A Nevada jury convicted Troy Don Brown of brutally raping a 9-year-old neighbor in 1994. The trial court and the Nevada Supreme Court rejected his appeals, in which he argued that the evidence did not prove him guilty beyond a reasonable doubt.

He then filed a federal habeas petition, claiming the lower courts' decision to uphold his conviction went against the Supreme Court's ruling in Jackson v. Virginia (1979), which required jurors to find proof beyond a reasonable doubt.

He introduced a DNA expert's opinion that the expert testimony at trial was inaccurate and unreliable, partly because it underestimated the likelihood that one of Brown's brothers would also match the DNA left at the crime scene.

The district court granted his petition and the 9th Circuit affirmed, saying the state high court had unreasonably applied Jackson.

The U.S. Supreme Court took up the case to decide two questions: the proper standard of review for a Jackson claim, and whether such a claim may rely on evidence outside the trial record.

Brown has since conceded that courts can't exclude the allegedly flawed trial evidence in deciding whether to overturn his conviction. A reviewing court must consider all of the evidence at trial when considering a Jackson claim, he acknowledged.

"[Brown's] concession thus disposes of his Jackson claim," the high court wrote.

The justices reversed the 9th Circuit's ruling for Brown, even though new evidence revealed that some of the trial evidence had likely been misleading, according to the report Brown presented.

"Regardless, ample DNA and non-DNA evidence in the record adduced at trial supported the jury's guilty verdict under Jackson, and we reject [Brown's] last-minute attempt to recast his claim," the justices ruled in the per curiam opinion.

The high court directed the 9th Circuit to also consider Brown's ineffective-assistance claims.

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