Background
Jordan Christopher Danski was convicted by a Michigan jury of first-degree home invasion and unlawfully driving away an automobile. The charges stemmed from a June 2015 incident where Amy Armstrong’s home was broken into and her Ford Focus was stolen. Evidence against Danski included cell phone location data placing him near the crime scene, fingerprints found inside the stolen vehicle, and an eyewitness identification of him behind the wheel of the car. During the trial, the court provided additional jury instructions on aiding-and-abetting liability sua sponte after the jury asked a question about the definition of driving. Danski was sentenced to thirteen to twenty years in prison. After state appeals were exhausted, Danski filed a federal petition for a writ of habeas corpus, arguing that the jury instructions violated his due process rights and that the evidence was insufficient to support his convictions.
The court’s reasoning
The court applied the Antiterrorism and Effective Death Penalty Act standard, which requires federal courts to defer to state court decisions unless they are contrary to or involve an unreasonable application of clearly established federal law. Regarding the jury instructions, the court found that the state court’s decision was not unreasonable because the charging documents provided notice of the aiding-and-abetting theory and there was evidence in the record to support it. The court noted that an erroneous instruction only warrants habeas relief if it renders the entire trial fundamentally unfair, a high bar Danski failed to meet. On the sufficiency of the evidence claim, the court applied a double layer of deference to the jury verdict and the state appellate court’s determination. The court concluded that the combination of cell phone data, fingerprints, eyewitness testimony, and Danski’s own statement provided a rational basis for the jury to find guilt beyond a reasonable doubt, even though the evidence was largely circumstantial.
The decision of the Michigan Court of Appeals does not run contrary to or unreasonably apply clearly established federal law.
Danski v. Miniard, 25-1287 (6th Cir. 2026)
What it means going forward
The ruling reinforces the high bar for federal habeas petitioners challenging state convictions based on jury instructions or sufficiency of evidence, particularly when the state court has already found a rational basis for the verdict and the defendant had notice of the theories of liability.