Also known as: legally-sufficient evidence · legal sufficiency of evidence · sufficiency of the evidence · legal sufficiency
Written by attorneys · grounded in primary & secondary sources — see below
Evidence that a reasonable factfinder could accept as adequate to support a particular finding or verdict. The standard requires only that the record contain proof from which a rational trier of fact could conclude that each essential element has been established.
After a bench trial, Layla Lane obtained judgment against Landmark Realty on a contract claim. Landmark moved to amend the findings, arguing the evidence on damages was too thin. The district court denied the motion. On appeal, Landmark may still question whether the evidence supporting the damages finding was legally sufficient even though it never objected before judgment.
Luna Lang was convicted of first-degree murder on circumstantial evidence that she purchased the murder weapon and was seen near the scene. In federal habeas, she argued no rational jury could have found premeditation. The court must decide whether the trial record contains legally sufficient evidence to support the state court's finding of guilt beyond a reasonable doubt.
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A jury convicted Levi Lowe of conspiracy but acquitted his co-defendant on the same evidence. Lowe moved for judgment of acquittal, claiming the verdicts showed the evidence was legally insufficient. The court upheld the conviction because the evidence against Lowe alone satisfied the sufficiency standard regardless of the acquittal of another party.
Lily Lopez was convicted of escape after presenting evidence that prison officials threatened her safety. She argued on appeal that the evidence of duress was legally sufficient to require an acquittal. The reviewing court examined whether a rational jury could have rejected the defense on the record presented at trial.
Lorenzo Lugo challenged his state conviction in federal habeas, claiming the evidence was legally insufficient under a newly announced constitutional standard. The court held that the new rule did not apply retroactively on collateral review because it was not a watershed rule of criminal procedure.
Latoya Lane was convicted of capital murder and later produced new affidavits suggesting another person committed the crime. She sought habeas relief on the ground that the new evidence showed her conviction rested on legally insufficient proof. The court required her to show that no rational jury could have found guilt beyond a reasonable doubt in light of the entire record.
A party may question the sufficiency of the evidence supporting the findings on appeal even if it never requested findings, objected to them, moved to amend them, or moved for partial findings before judgment.
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The party is barred on appeal from arguing that the evidence was legally insufficient to support the verdict, whether seeking judgment as a matter of law or a new trial.
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The reviewing court asks 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.
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…True, the methodology of particular studies may be challenged, and some of the figures arrived at may be disputed. But the sufficiency of the evidence before Congress to provide a rational basis for the finding cannot seriously be questioned. Cf. Turner Broadcasting System, Inc. v. FCC , 520 U. S. 180, 199 (1997) ("The Constitution gives…