What is the test for the adequacy of a jury trial waiver?

MultiRegion, United States of America

The following excerpt is from United States v. Laney, 881 F.3d 1100 (9th Cir. 2018):

We review de novo the adequacy of a jury trial waiver, United States v. Shorty , 741 F.3d 961, 965 (9th Cir. 2013). For a challenge to the sufficiency of the evidence following a bench trial, we review "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." United States v. Atkinson , 990 F.2d 501, 50203 (9th Cir. 1993) (internal citation and quotation omitted) (emphasis in original).

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