Lowell Jackson v. Jean Hill

MEMORANDUM

Lowell Edward Jackson appeals the judgment of the district court denying his 28 U.S.C. § 2254 petition for habeas corpus. Jackson was convicted in an Oregon bench trial of compelling and promoting the prostitution of a 15-year-old girl (“JB”).

As a threshold matter, Jackson contends that in rejecting his sufficiency claim, the district court improperly relied on the reasoning of the state post-conviction court. Although the district court endorsed the post-conviction court’s reasoning by referencing it in its opinion, such a passing reference does not indicate that the district court improperly abrogated its review of Jackson’s sufficiency claim. The district court’s thorough opinion demonstrates that it extensively examined the record in Jackson’s case. The brief reference to the post-conviction court’s similar determination regarding the weight of the evidence served only to bolster the district court’s independent analysis.

We conclude that, “after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” United States v. Nevils, 598 F.3d 1158,…