What is the test for establishing that poverty is not sufficient to prove motive for murder?

MultiRegion, United States of America

The following excerpt is from U.S. v. Mitchell, 172 F.3d 1104 (9th Cir. 1999):

The judge instructed the jury, using language from United States v. Jackson, 882 F.2d 1444 (9th Cir., 1989), that while poverty alone was insufficient to prove motive, evidence of an unexplained or abrupt improvement in financial circumstances might indicate commission of a crime:

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