What is the test for determining whether a reasonable trier of fact could have found defendant guilty beyond a reasonable doubt?

California, United States of America


The following excerpt is from People v. Adams, D065680 (Cal. App. 2015):

"In determining whether a reasonable trier of fact could have found defendant guilty beyond a reasonable doubt, the appellate court 'must view the evidence in a light most favorable to respondent and presume in support of the judgment the existence of every fact the trier could reasonably deduce from the evidence.' [Citations.] The court does not, however, limit its review to the evidence favorable to the respondent. . . . '[O]ur task . . . is twofold. First, we must resolve the issue in the light of the whole recordi.e., the entire picture of the defendant put before the juryand may not limit our appraisal to isolated bits of evidence selected by the respondent. Second, we must judge whether the evidence of each of the essential elements . . . is substantial; it is not enough for the respondent simply to point to "some" evidence supporting the finding, for "[n]ot every surface conflict of evidence remains substantial in the light of other facts." ' [Citation.]" (People v. Johnson (1980) 26 Cal.3d 557, 576-577.)

"When . . . the trier of fact has relied on inferences, those inferences must be reasonable." (People v. Holt (1997) 15 Cal.4th 619, 669.) An inference is not reasonable if it is " ' "based on suspicion alone, or on imagination, speculation, supposition, surmise, conjecture, or guess work. [] . . . A finding of fact must be an inference drawn from evidence rather than . . . a mere speculation as to probabilities without evidence." ' [Citation.]" (People v. Raley (1992) 2 Cal.4th 870, 891.)

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