What is the test for determining the sufficiency of evidence in a sexual assault case?

California, United States of America


The following excerpt is from People v. Costella, 11 Cal.App.5th 1, 217 Cal.Rptr.3d 343 (Cal. App. 2017):

Although defendant states this as a challenge to the sufficiency of the evidence, at the heart of this case lies a question of statutory interpretationthe meaning of forest landwhich we consider de novo. (People v. Prunty (2015) 62 Cal.4th 59, 71, 192 Cal.Rptr.3d 309, 355 P.3d 480.) To the extent we must determine whether there was sufficient evidence of forest land, we consider whether the record " "discloses substantial evidenceevidence that is reasonable, credible and of solid valuesuch that a reasonable trier of fact could find the defendant guilty beyond a reasonable doubt." " (People v. Brown (2014) 59 Cal.4th 86, 105, 172 Cal.Rptr.3d 576, 326 P.3d 188.)

Our primary task in interpreting the statute is to determine the lawmakers' intent. (Delaney v. Superior Court (1990) 50 Cal.3d 785, 798, 268 Cal.Rptr. 753, 789 P.2d 934.) We begin with the words of the statute and

[11 Cal.App.5th 6]

their usual and ordinary meaning, which would typically be their dictionary definition. (People v. Gonzalez (2008) 43 Cal.4th 1118, 1126, 77 Cal.Rptr.3d 569, 184 P.3d 702 ; Hammond v. Agran (1999) 76 Cal.App.4th 1181, 1189, 90 Cal.Rptr.2d 876.) Their plain meaning controls, unless the words are ambiguous. (People v. Gonzalez , supra , at p. 1126, 77 Cal.Rptr.3d 569, 184 P.3d 702.) "If the statute is ambiguous, we may consider a variety of extrinsic aids, including legislative history, the statute's purpose, and public policy." (Ibid . )

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