What is the standard of review on appeal when a defendant challenges the sufficiency of the evidence to support his conviction?

California, United States of America


The following excerpt is from People v. Smith, C076383 (Cal. App. 2016):

Where, as here, a defendant challenges the sufficiency of the evidence to support his conviction, the standard of review is well settled: "On appeal, the test of legal sufficiency is whether there is substantial evidence, i.e., evidence from which a reasonable trier of fact could conclude that the prosecution sustained its burden of proof beyond a reasonable doubt. [Citations.] Evidence meeting this standard satisfies constitutional due process and reliability concerns. [Citations.] [] While the appellate court must determine that the supporting evidence is reasonable, inherently credible, and of solid value, the court must review the evidence in the light most favorable to the [judgment], and must presume every fact the jury could reasonably have deduced from the evidence. [Citations.] Issues of witness credibility are for the jury." (People v. Boyer (2006) 38 Cal.4th 412, 479-480.)

"An appellate court must accept logical inferences that the [finder of fact] might have drawn from the circumstantial evidence." (People v. Maury (2003) 30 Cal.4th 342, 396.) "[A] jury may not rely upon unreasonable inferences, and . . . '[a]n inference is not reasonable if it is based only on speculation.' " (People v. Hughes (2002) 27 Cal.4th 287,

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365.) "Before the judgment of the trial court can be set aside for the insufficiency of the evidence, it must clearly appear that on no hypothesis whatever is there sufficient substantial evidence to support the verdict of the [finder of fact]." (People v. Hicks (1982) 128 Cal.App.3d 423, 429.)

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