What is the legal test for reversal of a jury's verdict for insufficient evidence?

California, United States of America


The following excerpt is from People v. Brown, B258677 (Cal. App. 2016):

In reviewing a challenge to the sufficiency of the evidence, we "review the whole record to determine whether any rational trier of fact could have found the essential elements of the crime . . . beyond a reasonable doubt. [Citation.] The record must disclose substantial evidence to support the verdicti.e., evidence that is reasonable, credible, and of solid valuesuch that a reasonable trier of fact could find the defendant guilty beyond a reasonable doubt. [Citation.] In applying this test, we review the evidence in the light most favorable to the prosecution and presume in support of the judgment the existence of every fact the jury could reasonably have deduced from the evidence. [Citation.]" (People v. Zamudio (2008) 43 Cal.4th 327, 357.) Thus, a "reversal for insufficient evidence 'is unwarranted unless it appears "that upon no hypothesis whatever is there sufficient substantial evidence to support"' the jury's verdict. [Citation.]" (Ibid.)

Page 9

The same standard governs in cases where the prosecution relies primarily on circumstantial evidence. (People v. Maury (2003) 30 Cal.4th 342, 403.) Accordingly, we "must accept logical inferences that the jury might have drawn from the circumstantial evidence. [Citation.]" (Ibid.)

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