Estelle v. McGuire

Summary

The Court reversed the Ninth Circuit's grant of habeas relief, holding that neither the admission of evidence of the victim's prior injuries nor the instruction governing its use violated due process. Federal habeas courts cannot reexamine state-law determinations, and the prior injuries were relevant to establish intentional injury rather than accident even without direct evidence connecting McGuire to them. Applying the reasonable-likelihood standard, the Court concluded that the instruction neither directed a finding that McGuire inflicted the prior injuries nor authorized propensity reasoning. It reaffirmed Boyde's standard and disapproved inconsistent standard-of-review language in Cage and Yates. Justice O'Connor, joined by Justice Stevens, agreed with Part I concerning admission of the evidence but dissented from Part II, concluding that the instruction might have relieved the prosecution of proving the killer's identity beyond a reasonable doubt; she would remand for harmless-error review. Justice Thomas did not participate.