In 1979's Jackson vs. Virginia case, the high court ruled that a state prisoner is entitled to help if a federal judge finds that "upon the record evidence adduced at the (state) trial no rational trier of fact could have found proof of guilt beyond a reasonable doubt."
Using Jackson, a federal judge and a divided federal appeals court granted constitutional review in the case of Troy Brown, who was convicted of raping a 9-year-old in 1994 in the small town of Carlin, Nev.
The girl was unable to effectively identify her night attacker, described clothing that was somewhat inconsistent with what Brown wore and said she thought she had bitten her attacker -- though police found no bite mark on the suspect. There were no Brown fingerprints in the girl's trailer.
Sperm from the girl's panties and a rape kit showed that its DNA matched Brown with a 1 in 3 million probability. Before sentencing, Brown's family had the DNA tested, and those results showed a 1 in 10,000 probability.
Brown was sentenced to life in prison. State courts rejected his appeals.
In his federal appeal 11 years after conviction, Brown argued that the state DNA expert erroneously described the probabilities, and did not accurately describe whether the DNA would match one of his brothers. Federal courts agreed with him.
In knocking down the lower-court federal rulings Monday, the Supreme Court said "DNA and non-DNA evidence in the record adduced at trial supported the jury's guilty verdict under Jackson. ... "