Whether the standard for reviewing the sufficiency of evidence under Jackson v. Virginia permits a conviction to be upheld when the evidence is acknowledged as weak and does not exclude every reasonable hypothesis of innocence

No question identified. : No. IN THE SUPREME COURT OF THE UNITED STATES October Term, 2024 SONYA FULLER, Petitioner, v. GEORGIA, Respondent. APPLICATION FOR EXTENSION OF TIME TO FILE PETITION FOR WRIT OF CERTIORARI TO THE SUPREME COURT OF GEORGIA TO THE HONORABLE CLARENCE THOMAS, Associate Justice of the Supreme Court of the United States, and Circuit Justice for the Eleventh Circuit: Petitioner Sonya Fuller, by and through undersigned counsel and pursuant to Supreme Court Rule 13, respectfully requests an extension of time of thirty (30) days to file her Petition for Writ of Certiorari in this Court. Fuller seeks review of the decision of the Supreme Court of Georgia affirming the conviction and sentence in this case. Fuller invokes the jurisdiction of this Court pursuant to 28 U.S.C. § 1257(a). Her time to file a Petition for Writ of Certiorari in this Court elapses on October 14, 2025'; therefore, she makes this request more than ten (10) days before the date her petition would be due without an extension of time. In support of this request, Fuller shows the following as good cause: In 2021, Fuller was charged with multiple counts of felony murder and other underlying felonies for her alleged involvement in the shooting death of Anthony Reid. See App. A at 7 (Fuller v. State, 917 S.E.2d 623, 624 n.1 (Ga. 2025)). At her trial in 2022, a Spalding County jury acquitted her of most charges. However, the jury found her guilty of one count of felony murder, one count of aggravated assault, and one count of hindering the apprehension of a criminal. /d. Following her conviction, Fuller was sentenced to life without the possibility of parole, plus an additional 5 years imprisonment. Jd. Fuller appealed her conviction to the Supreme Court of Georgia, where she argued that the evidence was insufficient to sustain her conviction. In a sharply divided opinion, that court affirmed. A majority of the court acknowledged that “the evidence of Fuller’s guilt was not strong,” but nevertheless concluded that the evidence was constitutionally sufficient under the standard set in Jackson v. ' The ordinary deadline for the petition is Monday, October 13, 2025, but that is a federal legal holiday. As a result, the deadline for the petition is the next business day. See Sup. Ct. R. 30(1). 2 Virginia, 443 U.S. 307 (1979). App. A at 3. Two Justices concurred, expressing their view that while the evidence “just barely” passed constitutional muster, it did not exclude every reasonable hypothesis of innocence. App. A at 4. Three Justices dissented and would have “reverse[d] Fuller’s conviction for felony murder” on sufficiency grounds. App. A at 4. The court subsequently denied Fuller’s request for reconsideration. See App. B. A petition for certiorari in this case is essential because Fuller’s case raises important questions regarding the proper application of this Court’s Jackson decision. Undersigned counsel were not involved in the prior proceedings in this case and need additional time to adequately present the claim to this Court. Undersigned counsel respectfully request this extension of time because of the importance of the issues in this case and counsel’s obligations in other cases. With an extension of thirty (30) days, undersigned counsel are confident that they can present the relevant issues to this Court. THEREFORE, Fuller respectfully requests that this Court grant her a thirty (30) day extension of time within which to file her petition for a writ of certiorari, up to and including November 13, 2025. Respectfully submitted, this 11th day of September, 2025. /s/ Michael Admirand MICHAEL ADMIRAND Counsel of Record KATHERINE MOSS Southern Center for Human Rights 60 Walton Street NW Atlanta, GA 30303 Tel: 404-688-1202 Fax: 404-688-9440 madmirand@schr.org kmoss@schr.org