The following excerpt is from Ward v. McDowell, Case No.: 16cv3055-DMS-MDD (S.D. Cal. 2017):
The Fourteenth Amendment's Due Process Clause protects criminal defendants from convictions "except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime with which he is charged." In re Winship, 397 U.S. 358, 364 (1970). In a federal habeas proceeding, a petitioner challenging the sufficiency of the evidence may obtain relief only if "it is found that upon the record evidence adduced at the trial no rational trier of fact could have found proof of guilt beyond a reasonable doubt." Jackson v. Virginia, 443 U.S. 307, 324 (1979). "[T]he relevant question is 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." Id. at 319 (emphasis in original). A reversal for insufficiency of the evidence is essentially a "determination that the government's case against the defendant was so lacking that the trial
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