Waddington v. Sarausad: Facts, Decision, & Significance

Instructor: Michelle Penn

Michelle has a J.D. and her PhD in History.

In this lesson we learn about the 2009 Supreme Court case Waddington v. Sarausad, including the background to the case, the Court's holding, and its significance regarding accomplice liability.

Background to the Case

The shooting took place in Seattle.
Image of city of Seattle

In the case of Waddington v. Sarausad, Cesar Sarausad II was the driver of a car involved in shooting at a group of students standing in front of a Seattle high school. Sarausad belonged to a gang, as did the gunman. Sarausad drove the gunman, Brian Ronquillo, to the school, where he fatally shot one student and wounded another.

The Trial

Sarausad was charged as an accomplice in the murder of the student, and the attempted murder and assault of other students. Washington state law said that accomplice liability in the commission of a crime, or holding a person criminally liable for the actions of another, applies when someone promotes or facilitates the commission of a crime, when the person ''solicits, commands, encourages, or requests another person to commit the crime,'' or ''aids or agrees to aid another person in planning or committing the crime.''

Arguing that he was not an accomplice to the crime, Sarausad claimed at trial that he expected at most a fistfight with the students, as he did not know Ronquillo was armed, and was completely surprised when Ronguillo fired at the students. The prosecutor said that because Sarausad slowed down outside the high school, and drove away quickly after the shooting, he must have been a willing participant in the shooting.

The jury asked for clarification three times about accomplice liability, including whether someone's willing participation in a group activity makes ''that person an accomplice to any crime committed by anyone in the group.'' In response to these inquiries, the jury was simply told to reread the instructions. While the jury found Ronquillo guilty on all counts (including first-degree murder), they only found Sarausad guilty of second-degree murder, attempted second-degree murder, and second-degree assault.


Sarausad appealed the trial court's decision, arguing that the State didn't prove beyond a reasonable doubt that he intended to kill anyone, and thus that he could not be considered an accomplice. Both the Washington Court of Appeals and the Washington Supreme Court affirmed Sarausad's convictions. Sarausad then argued that instructions given to the jury may have led them to wrongly convict him, but on this issue the Washington Court of Appeals and the Washington Supreme Court disagreed with him and again affirmed the trial court's convictions.

Finally, Sarausad filed a writ of habeas corpus in federal district court. Habeas corpus dates back to medieval times and in Latin means ''you shall have the body,'' meaning that a person is alleging they are wrongfully detained. The district court found that the jury was confused about what needed to be established for Sarausad to be guilty as an accomplice, and the Court of Appeals for the Ninth Circuit affirmed the district court's holding. They agreed that the jury instructions were unclear on whether Sarasuad could be convicted of murder and attempted murder as an accomplice without proving beyond a reasonable doubt that he knew Ronquillo intended to commit a murder.

The state of Washington appealed to the Supreme Court, arguing that habeas corpus should not have been granted.

The Supreme Court's Holding

Justice Clarence Thomas wrote the opinion for the Supreme Court.
picture of Clarence Thomas

The Supreme Court sided with the trial court, upholding Sarausad's state convictions and reversing the federal courts' decisions. The Court said that the ability of federal courts to grant habeas corpus relief on a claim adjudicated in state courts was limited only to situations in which the state court decision ''was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States.'' This standard is known as ''objectively unreasonable.'' Sarasusad needed to show ''both that the instruction was ambiguous and that there was 'a reasonable likelihood' that the jury applied the instruction in a way that relieved the State of its burden of proving every element of the crime beyond a reasonable doubt.''

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