Is there sufficient evidence to support a jury's inference of specific intent to deceive?

California, United States of America


The following excerpt is from People v. Daniels, B276282 (Cal. App. 2017):

Defendant argues that this evidence is insufficient because it is circumstantial and because her testimony showed that she did not intend to deceive. Yet, "[s]pecific intent may be, and usually must be, inferred from circumstantial evidence." (People v. Cole (1985) 165 Cal.App.3d 41, 48.) Here, there was plenty of documentary evidence and testimony by DPSS workers to support the jury's inference of specific intent to deceive.

Defendant argues that the evidence was susceptible to two reasonable conclusions, one of which pointed to defendant not having the requisite intent, and thus "the jury was sworn to find her not guilty." Defendant's point confuses the duties of a jury and those of an appellate court in considering reasonable inferences. Defendant is essentially asking this court to reweigh the evidence before the jury, which we may not do on appeal. "We 'must accept logical inferences that the jury might have drawn from the circumstantial evidence. [Citation.]' [Citation.] 'Although it is the jury's duty to acquit a defendant if it finds the circumstantial evidence susceptible of two reasonable interpretations, one of which suggests guilt and the other innocence, it is the jury, not the appellate court that must be convinced of the defendant's guilt beyond a reasonable doubt. [Citation.]' [Citation.] Where the circumstances reasonably justify the trier of fact's findings, a reviewing court's conclusion the circumstances might also reasonably be reconciled with a contrary finding does not warrant the judgment's reversal. [Citation.]" (People v. Zamudio (2008) 43 Cal.4th 327, 357-358.)

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