Maquiz MacDonald v. Hedgpeth, No. 16-55240 (9th Cir. 2018)
Annotate this Case
The Ninth Circuit reversed the district court's denial of habeas relief to petitioner, holding that the state trial court's admission of opinion testimony from a law enforcement expert on street gangs, who described for the jury the potential benefits that a street gang might receive when a member commits a robbery by himself, did not deny petitioner a fundamentally fair trial and due process. The panel held that the district court's judgment was not contrary to, or an unreasonable application of, Supreme Court precedent.
However, the panel explained that the expert testimony was insufficient to support a ten-year gang enhancement and that the state court's decision was an unreasonable application of Jackson v. Virginia, 443 U.S. 307 (1979). Furthermore, no rational trier of fact could have found this expert testimony by itself sufficient to prove the elements of the 2001 robbery gang enhancement beyond a reasonable doubt.
Court Description: Habeas Corpus. The panel reversed the district court’s denial of a habeas corpus petition brought by California state prisoner Felix Estuardo Maquiz MacDonald (Maquiz), and remanded regarding imposition of a gang enhancement pursuant to California Penal Code § 186.22(b)(1) to Maquiz’s sentence for a robbery conviction. The panel held that the state trial court’s admission of opinion testimony from a law enforcement expert on street gangs, who described for the jury the potential benefits that a street gang might receive when a member commits a robbery by himself, did not deny Maquiz a fundamentally fair trial and due process, and was not contrary to, or an unreasonable application of, Supreme Court precedent. The panel held that such expert testimony was, however, insufficient to support Maquiz’s ten-year gang enhancement to his sentence for a robbery that he committed alone. The panel held that the state court’s decision was an unreasonable application of Jackson v. Virginia, 443 U.S. 307 (1979), and no rational trier of fact could have found this
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.