What is the test for the sufficiency of evidence to support a criminal conviction?

MultiRegion, United States of America

The following excerpt is from U.S. v. Edwards, 991 F.2d 804 (9th Cir. 1993):

We review the sufficiency of the evidence to support a criminal conviction by asking "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." Jackson v. Virginia, 443 U.S. 307, 319 (1979) (citation omitted).

Appellant argues that no rational trier of fact could have concluded that the appellant committed the robbery because the witness identifications of the appellant as the bank robber were not credible. Jury determinations of witness credibility are generally unreviewable on appeal. See United States v. Gillock, 886 F.2d 220, 222 (9th Cir.1989); Nicholson v. Rushen, 767 F.2d 1426, 1427 (9th Cir.1985). We see no reason to deviate from that general rule here. Since appellant's sufficiency challenge rests entirely on his view that the witnesses were not credible, we hold that the evidence was sufficient to sustain appellant's convictions.

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