What is the standard of review for a defendant's claim of insufficiency of evidence?

California, United States of America


The following excerpt is from People v. Yohannes, A131843 (Cal. App. 2015):

"In assessing a claim of insufficiency of evidence," our task as a reviewing court is "to review the whole record in the light most favorable to the judgment to determine whether it discloses substantial evidence that is, evidence that is reasonable, credible, and of solid value such that a reasonable trier of fact could find the defendant guilty beyond a reasonable doubt. [Citation.] The federal standard of review is to the same effect: Under principles of federal due process, review for sufficiency of evidence entails not the determination whether the reviewing court itself believes the evidence at trial establishes guilt beyond a reasonable doubt, but, instead, whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt." (People v. Rodriguez (1999) 20 Cal.4th 1, 11.) As we now discuss, we see no merit to defendant's challenges to the sufficiency of the evidence to support the lack of consent and asportation elements of the substantive crime of aggravated kidnapping and the aggravated kidnapping sentence enhancement concerning defendant's criminal conduct against T.

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