What is the test for sufficiency of evidence in a motor vehicle case?

California, United States of America


The following excerpt is from People v. Bernal, E064221 (Cal. App. 2017):

In reviewing a challenge of the sufficiency of the evidence, "[We] consider the evidence in a light most favorable to the judgment and presume the existence of every fact the trier could reasonably deduce from the evidence in support of the judgment. The test is whether substantial evidence supports the decision, not whether the evidence proves guilt beyond a reasonable doubt." (People v. Mincey (1992) 2 Cal.4th 408, 432, fn. omitted.)

"[Vehicle Code] [s]ection 2800.2 makes it a crime for a motorist to flee from, or attempt to elude, a pursuing peace officer's vehicle in 'violation of Section 2800.1' and 'in a willful or wanton disregard for the safety of persons or property.' Under [Vehicle Code] section 2800.1, a person who operates a motor vehicle 'with the intent to evade, willfully flees or otherwise attempts to elude a pursuing peace officer's motor vehicle, is guilty of a misdemeanor . . . if all of the following conditions exist: [] (1) The peace officer's motor vehicle is exhibiting at least one lighted red lamp visible from the front and the person either sees or reasonably should have seen the lamp. [] (2) The peace officer's motor vehicle is sounding a siren as may be reasonably necessary. [] (3) The peace officer's motor vehicle is distinctively marked. [] (4) The peace officer's motor vehicle is operated by a peace officer . . . wearing a distinctive uniform.' . . . Thus, the statute requires four distinct elements, each of which must be present: (1) a red light, (2) a siren, (3) a distinctively marked vehicle, and (4) a peace officer in a distinctive uniform." (People v. Hudson (2006) 38 Cal.4th 1002, 1007-1008, italics omitted.)

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