What is the test to determine insufficient evidence in a criminal case?

California, United States of America


The following excerpt is from People v. Mendoza, 59 Cal.App.4th 1333, 69 Cal.Rptr.2d 728 (Cal. App. 1997):

"The proper test to determine a claim of insufficient evidence in a criminal case is whether, on the entire record, a rational trier of fact could find appellant guilty beyond a reasonable doubt. (People v. Johnson (1980) 26 Cal.3d 557, 576-578, 162 Cal.Rptr. 431, 606 P.2d 738; Jackson v. Virginia (1979) 443 U.S. 307, 318-319, 99 S.Ct. 2781, 2788-2789, 61 L.Ed.2d 560.) In making this determination, the appellate court 'must view the evidence in a light most favorable to respondent and presume in support of the judgment the existence of every fact the trier could reasonably deduce from the evidence.' [Citations.] ... '[O]ur task ... is twofold. First, we must resolve the issue in the light of the whole record . ... Second, we must judge whether the evidence of each of the essential elements ... is substantial . ...' " (People v. Johnson, supra, 26 Cal.3d at pp. 576-577, 162 Cal.Rptr. 431, 606 P.2d 738, italics in original.)

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