California, United States of America
The following excerpt is from People v. Vinson, B238043 (Cal. App. 2013):
Additionally, the People claim, even if the verdict as to attempted voluntary manslaughter was inconsistent with the verdicts on the other counts, that does not provide a basis for reversing the conviction. "As a general rule, inherently inconsistent verdicts are allowed to stand. [Citations.]" (People v. Avila (2006) 38 Cal.4th 491, 600.) As explained in People v. Superior Court (Sparks) (2010) 48 Cal.4th 1, "'[t]he law generally accepts inconsistent verdicts as an occasionally inevitable, if not entirely satisfying, consequence of a criminal justice system that gives defendants the benefit of a reasonable doubt as to guilt, and juries the power to acquit whatever the evidence.' [Citation.]" (Id. at p. 13.) Even where the verdicts are inconsistent, the "'"defendant already is afforded protection against jury irrationality or error by the independent review of the sufficiency of the evidence undertaken by the trial and appellate courts."'" (Ibid.) So long as there is sufficient evidence to support the defendant's conviction beyond a reasonable doubt, no "'"further safeguards against jury irrationality are necessary."'" (Ibid.)
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