Also known as: legally sufficient · legal sufficiencies · sufficiency of the evidence
Written by attorneys · grounded in primary & secondary sources — see below
Evidence that a reasonable factfinder could accept as establishing a required element or claim. The standard measures whether the record contains enough probative material to support a verdict or finding rather than whether the evidence is overwhelming or undisputed.
After a bench trial, the district court entered judgment for the defendant on the basis of sparse findings that the plaintiff had failed to carry its burden on volume estimates. The plaintiff appealed without having requested findings or objected before judgment. The appellate court permitted the plaintiff to question whether the evidence supported the findings because Rule 52(a)(5) preserves that right regardless of prior requests or objections.
A state jury convicted the defendant of first-degree murder on circumstantial evidence that he had shot the victim. The defendant sought federal habeas relief arguing the evidence could not support the verdict. The reviewing court applied the legal-sufficiency standard to determine whether any rational trier of fact could have found the essential elements beyond a reasonable doubt.
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A jury acquitted the defendant on some counts but convicted on others arising from the same facts. The defendant moved to set aside the convictions on the ground that the acquittals rendered the evidence legally insufficient to support the guilty verdicts. The court upheld the convictions because legal sufficiency is assessed independently for each count.
The government charged a former governor with accepting gifts in exchange for official acts. The jury instructions broadly defined official acts to include any action on any matter before the government. The defendant challenged the legal sufficiency of the evidence under the correct narrower definition of official act.
Police found the defendant behind the wheel of a running car parked on a private driveway at night. The prosecution offered only that circumstance to prove knowing possession of contraband inside the vehicle. The court assessed whether the single circumstance supplied a legally sufficient basis for a reasonable jury to find the element.
A court of appeals reversed a conviction for insufficient evidence and ordered a new trial. The defendant argued that the double-jeopardy clause barred retrial once the evidence had been found legally insufficient. The Supreme Court held that reversal for legal insufficiency terminates the prosecution and precludes retrial.
The court asks whether a reasonable jury would have a legally sufficient evidentiary basis to find for the nonmovant on the issue. If the record lacks such a basis the court may resolve the issue against the party and enter judgment.
Supporting sources
Yes. Rule 52(a)(5) expressly permits a party to question the sufficiency of the evidence supporting the findings whether or not the party requested findings, objected to them, moved to amend them, or moved for partial findings.
Supporting sources
The double-jeopardy clause bars retrial. The reversal for insufficient evidence terminates the prosecution and the defendant may not be retried on the same charge.
No. Legal sufficiency is evaluated independently for each count. Inconsistent verdicts do not require reversal on sufficiency grounds.
…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…