What is a defendant's burden in challenging his criminal conviction?

MultiRegion, United States of America

The following excerpt is from United States v. Ibrahim, No. 19-823 (2nd Cir. 2020):

A defendant bears "a heavy burden" in challenging the sufficiency of the evidence underlying his criminal conviction. United States v. Archer, 671 F.3d 149, 160 (2d Cir. 2011). We must affirm a conviction if we determine that "any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt." United States v. Babilonia, 854 F.3d 163, 174 (2d Cir. 2017) (emphasis omitted). In making this determination, we are required to "view the evidence in the light most favorable to the government, crediting every inference that could have been drawn in the government's favor, and deferring to the jury's assessment of witness credibility and its assessment of the weight of the evidence." Id. The

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government, moreover, is "not required to preclude every reasonable hypothesis that is consistent with innocence," Archer, 671 F.3d at 160 (internal quotation marks and brackets omitted), and it may rely on circumstantial evidence alone to prove the mens rea requirements of a crime, see United States v. MacPherson, 424 F.3d 183, 189-90 (2d Cir. 2005).

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