Owens v. Duncan

Ramon Nelson was killed by a blow to the head. Two eyewitnesses, Maurice Johnnie and William Evans, identified Lawrence Owens (defendant) as the murderer from a photo array and lineup. Owens was charged with murder. At trial, Evans twice pointed at someone other than Owens from a photo array when asked to identify the suspect. Further, Evans and Johnnie offered conflicting testimony regarding the number of assailants and whether Nelson spoke to any assailant before the attack. Although the evidence suggested that Nelson sold illegal drugs, no evidence at trial was presented to show that Owens knew Nelson or knew that Nelson was a drug dealer. No physical evidence connecting Owens to Nelson’s murder was presented. The murder occurred during twilight when the area was already dark, which affected visibility. After a bench trial, the judge found Owens guilty, explaining that the witnesses had “skirted the real issue.” The judge identified the real issue as the fact that Owens knew Nelson and knew that Nelson was a drug dealer, and the judge concluded that the state had proven this. Owens appealed. The appellate court questioned the reliability of Evans’s testimony and found no evidence at trial that Owens knew that Nelson was involved with illegal drugs and that the judge’s belief to this effect was baseless. However, the appellate court held that the judge’s error was harmless because Johnnie’s identification of Owens was sufficient to establish Owens’s guilt. After exhausting state court appeals, Owens petitioned the federal court for habeas corpus, which was denied. Owens again appealed, arguing that he was convicted based on evidence that did not exist in violation of Owen’s right to the due process of law.