What is the burden of proving insufficient on all counts?

MultiRegion, United States of America

The following excerpt is from U.S. v. Coyne, 4 F.3d 100 (2nd Cir. 1993):

Appellant argues that the evidence was insufficient on all counts. However, he has failed to meet the "heavy burden" of showing that no rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt after all inferences are drawn in favor of the government. United States v. Butler, 970 F.2d 1017, 1021-22 (2d Cir.), cert. denied, --- U.S. ----, 113 S.Ct. 480, 121 L.Ed.2d 386 (1992).

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