What is the test for sufficiency of evidence under the Fourteenth Amendment?

California, United States of America


The following excerpt is from People v. Alvarez, 14 Cal.4th 155, 58 Cal.Rptr.2d 385, 926 P.2d 365 (Cal. 1996):

"In reviewing the sufficiency of evidence under the due process clause of the Fourteenth Amendment to the United States Constitution, the question we ask 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.' " (People v. Rowland, supra, 4 Cal.4th at p. 269, 14 Cal.Rptr.2d 377, 841 P.2d 897, quoting Jackson v. Virginia (1979) 443 U.S. 307, 319, 99 S.Ct. 2781, 2789, 61 L.Ed.2d 560, italics in original.)

Defendant claims that the evidence is insufficient to support his first degree murder conviction under the theory of felony-murder robbery or attempted robbery on the ground that it is inadequate to establish intent to steal--which is an element of robbery and attempted robbery (see, e.g., People v. Ledesma (1987) 43 Cal.3d 171, 243, 233 Cal.Rptr. 404, 729 P.2d 839).

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