painstaking analysis in Minnesota

2026Under the traditional standard, the reviewing court conducts “a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the jurors to reach the verdict which they did.” State v. Webb, 440 N.W.2d 426, 430 (Minn. 1989).

2024When performing a sufficiency-of-the-evidence review, we conduct “a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the jurors to reach the verdict which they did.” State v. Webb, 440 N.W.2d 426, 430 (Minn. 1989).

2024In analyzing an argument that the evidence is insufficient to support a conviction, this court ordinarily undertakes “a painstaking analysis of the record to determine whether 5 the evidence, when viewed in the light most favorable to the conviction, was sufficient.” State v. Ortega, 813 N.W.2d 86, 100 (Minn. 2012) (quotation omitted).

2018When considering a challenge to the sufficiency of the evidence, we conduct "a painstaking analysis of the record to determine whether the evidence, when viewed in the light most favorable to the conviction, was sufficient to permit the jurors to reach the verdict which they did." State v. Ortega , 813 N.W.2d 86 , 100 (Minn. 2012) (quotation omitted).

2017In considering a challenge to the sufficiency of the evidence, our role is “limited to a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the jurors to reach their verdict.” State v. Caine, 746 N.W.2d 339, 356 (Minn. 2008).

2015When considering a claim of insufficient evidence, we conduct “a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the jurors to reach their verdict.” State v. Caine, 746 N.W.2d 339, 356 (Minn. 2008) (quotation omitted).

2016We assume that the fact-finder “believed the state’s witnesses and disbelieved any evidence to the contrary.” State v. Moore, 438 N.W.2d 101, 108 (Minn. 1989).

2016We assume “the jury believed the state’s witnesses and disbelieved any evidence to the contrary.” State v. Moore, 438 N.W.2d 101, 108 (Minn. 1989).

2026Under the direct-evidence standard, “we limit our review to a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit 7 the jurors to reach the verdict which they did.” State v. Horst, 880 N.W.2d 24, 40 (Minn. 2016) (quotation omitted).

2025When a conviction is supported by direct evidence, “we limit our review to a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the jurors to reach the verdict which they did.” Horst, 880 N.W.2d at 40 (quotation omitted).

2017Our review of a sufficiency-of-the-evidence challenge is “limited to a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the jurors to reach the verdict which they did.” State v. DeRosier, 695 N.W.2d 97, 108 (Minn. 2005) (quotation omitted).

2016DECISION Our review of a sufficiency-of-the-evidence challenge is “limited to a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the [fact-finder] to reach the verdict which [it] did.” State v. DeRosier, 695 N.W.2d 97, 108 (Minn. 2005) (quotation omitted).

2024A conviction will not be reversed “if [a] jury, acting with due regard for the presumption of innocence and for the necessity of overcoming it by proof beyond a reasonable doubt, could reasonably conclude that a defendant was proven guilty of the offense charged.” Bernhardt v. State, 684 N.W.2d 465, 476-77 (Minn. 2004) (quotation omitted).

2017“We will not disturb the verdict if the jury, acting with due regard for the presumption of innocence and for the necessity of overcoming it by proof beyond a reasonable doubt, could reasonably conclude that a defendant was proven guilty of the offense charged.” Bernhardt v. State, 684 N.W.2d 465, 476-77 (Minn. 2004) (quotation omitted).

2019This court assumes "that the jury believed all of the state's witnesses and disbelieved any evidence to the contrary." State v. Chambers , 589 N.W.2d 466 , 477 (Minn. 1999).

2015We must assume “the jury believed the state’s witnesses and disbelieved any evidence to the contrary.” State v. Chambers, 589 N.W.2d 466, 477 (Minn. 1999).

2026We “carefully examine the record to determine whether the facts and the legitimate inferences drawn from them would permit the factfinder to reasonably conclude that the defendant was guilty beyond a reasonable doubt of the offense of which he was convicted.” State v. Waiters, 929 N.W.2d 895, 900 (Minn. 2019) (quotation omitted).

2026We “carefully examine the record to determine whether the facts and the legitimate inferences drawn from them would permit the factfinder to reasonably conclude that the defendant was guilty beyond a reasonable doubt of the offense of which he was convicted.” State v. Waiters, 929 N.W.2d 895, 900 (Minn. 2019) (quotation omitted).

2015DECISION Our review of the sufficiency of the evidence is “‘limited to a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the jurors to reach the verdict which they did.’” State v. Fields, 679 N.W.2d 341, 348 (Minn. 2004) (quoting State v. Webb, 440 N.W.2d 426, 430 (Minn. 1989)).

2014A. Standard of Review This court’s “review of the sufficiency of the evidence is ‘limited to a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the jurors to reach the verdict which they did.’” State v. Fields, 679 N.W.2d 341, 348 (Minn. 2004) (quoting State v. Webb, 4 440 N.W.2d 426, 430 (Minn. 1989)).

2024We assume that “the jury believed the state’s witnesses and disbelieved any evidence to the contrary.” State v. Caldwell, 803 N.W.2d 373, 384 (Minn. 2011) (quotation omitted).

2017See State v. Kramer, 668 N.W.2d 32, 37 (Minn. App. 2003) (stating that question of whether affirmative defense of mistake of age was proved by a preponderance of the evidence “is akin to a challenge to the sufficiency of the evidence”), review denied (Minn. Nov. 18, 2003). 4 Our review “is limited to a painstaking analysis of the record to determine whether the evidence, when viewed in the light most favorable to the verdict, is sufficient to allow the jurors to reach the verdict that they did.” State v. Caldwell, 803 N.W.2d 373, 384 (Minn. 2011).

2015We must assume that “the jury believed the State’s witnesses and disbelieved the defense witnesses.” State v. Tscheu, 758 N.W.2d 849, 858 (Minn. 2008).

2015We must assume that “the jury believed the State’s witnesses and disbelieved the defense witnesses.” State v. Tscheu, 758 N.W.2d 849, 858 (Minn. 2008).

2014“In reviewing a sufficiency of the evidence claim, [appellate courts] are limited to a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the [decision-maker] to reach [its] verdict.” State v. Hatfield, 639 N.W.2d 372, 375 (Minn. 2002).

2008When a conviction is challenged based on sufficiency of the evidence, “we are limited to a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the jurors to reach their verdict.” State v. Hatfield, 639 N.W.2d 372, 375 (Minn.2002).

2014The court “will construe the record most favorably to the state and will assume the evidence supporting the conviction was believed and the contrary evidence disbelieved.” State v. Pieschke, 295 N.W.2d 580, 584 (Minn. 1980).

2014The court “will construe the record most favorably to the state and will assume the evidence supporting the conviction was believed and the contrary evidence disbelieved.” State v. Pieschke, 295 N.W.2d 580, 584 (Minn. 1980).

2012When considering a claim of insufficient evidence, our review “is limited to a painstaking analysis of the record to determine whether the evidence, when viewed in the light most favorable to the conviction, was sufficient to permit the jurors to reach the verdict which they did.” State v. Webb, 440 N.W.2d 426, 430 (Minn.1989) (citing State v. Martin, 293 N.W.2d 54, 55 (Minn.1980)).

2009When reviewing the sufficiency of the evi *93 dence to support a conviction, we conduct “a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the jurors to reach the verdict which they did.” State v. Webb, 440 N.W.2d 426, 430 (Minn.1989) (citing State v. Martin, 293 N.W.2d 54, 55 (Minn.1980)).

2024But if a conviction is based on circumstantial evidence—or “evidence from which the factfinder can infer whether the facts in dispute existed or did not exist,” Harris, 895 N.W.2d at 599 (quotation omitted), then we apply a two-step analysis, State v. Silvernail, 831 N.W.2d 594, 598-99 (Minn. 2013).

2015In the circumstantial evidence context, the Minnesota Supreme Court has repeatedly held that when the state’s case is based largely, or entirely, on circumstantial evidence, there is sufficient evidence to sustain a conviction if and only if “no other reasonable, rational inferences [exist] that are inconsistent with guilt.” State v. Al-Naseer, 788 N.W.2d 469, 474 (Minn.2010); see also State v. Silvemail, 831 N.W.2d 594, 599 (Minn.2013).

2024See Harris, 895 N.W.2d at 599 .

2024But if a conviction is based on circumstantial evidence—or “evidence from which the factfinder can infer whether the facts in dispute existed or did not exist,” Harris, 895 N.W.2d at 599 (quotation omitted), then we apply a two-step analysis, State v. Silvernail, 831 N.W.2d 594, 598-99 (Minn. 2013).

2016State v. Caine, 746 N.W.2d 339, 356 (Minn. 2008) (quotation omitted); see also State v. Palmer, 803 N.W.2d 727, 733 (Minn. 2011) (stating that, when evaluating the sufficiency of evidence, the same standard of review applies to court trials as to jury trials).

2016State v. Caine, 746 N.W.2d 339, 356 (Minn. 2008) (quotation omitted); see also State v. Palmer, 803 N.W.2d 727, 733 (Minn. 2011) (stating that, when evaluating the sufficiency of evidence, the same standard of review applies to court trials as to jury trials).

2015“If a conviction, or a single element of a criminal offense, is based solely on circumstantial evidence,” Fairbanks, 842 N.W.2d at 307 , “[appellate courts] apply a two- step analysis in determining whether [that] circumstantial evidence is sufficient to 3 support a guilty verdict,” State v. Moore, 846 N.W.2d 83, 88 (Minn. 2014).

2015“If a conviction, or a single element of a criminal offense, is based solely on circumstantial evidence,” Fairbanks, 842 N.W.2d at 307 , “[appellate courts] apply a two-step analysis in determining whether [that] circumstantial evidence is sufficient to support a guilty verdict,” State v. Moore, 846 N.W.2d 83, 88 (Minn. 2014).

1999“The conviction *370 may only stand where the circumstances form ‘a complete chain which, in light of the evidence as a whole, leads so directly to the guilt of the accused as to exclude, beyond a reasonable doubt, any reasonable inference other than that of guilt.’ ” State v. Bias, 419 N.W.2d 480, 484 (Minn.1988) (quoting State v. Wahlberg, 296 N.W.2d 408, 411 (Minn.1980)).

1990In making this determination, the reviewing court must “assume the [trier of fact] believed the state’s witnesses and disbelieved any contrary evidence.” State v. Bias, 419 N.W.2d 480, 484 (Minn.1988).

2035The weight and credibility of the testimony of individual 1 The supreme court in Kemp expressed concern that the complaining witness in that case was not impeached with prior inconsistent statements that may have cast doubt on his credibility with the fact-finder. 138 N.W.2d at 611-12.

2035The weight and credibility of the testimony of individual 1 The supreme court in Kemp expressed concern that the complaining witness in that case was not impeached with prior inconsistent statements that may have cast doubt on his credibility with the fact-finder. 138 N.W.2d at 611-12 .

2035We are not persuaded to depart from current supreme court caselaw, which defers to the fact-finder’s credibility determinations, see Carufel, 783 N.W.2d at 546 (“[O]ur review on appeal is limited to a painstaking analysis of the record to determine whether the evidence . . . was sufficient to permit the jurors to reach the verdict which they did.

2035We are not persuaded to depart from current supreme court caselaw, which defers to the fact-finder’s credibility determinations, see Carufel, 783 N.W.2d at 546 (“[O]ur review on appeal is limited to a painstaking analysis of the record to determine whether the evidence . . . was sufficient to permit the jurors to reach the verdict which they did.

2024Generally, “a conviction can rest on the uncorroborated testimony of a single credible witness.” State v. Foreman, 680 N.W.2d 536, 539 (Minn. 2004) (quotation omitted).

2023State v. Blevins, 757 N.W.2d 698, 700 (Minn. App. 2008).

2017This court’s review of appellant’s insufficient-evidence claim “is limited to a painstaking analysis of the record to determine whether the evidence . . . was sufficient to permit the jurors to reach the verdict which they did.” State v. Webb, 440 N.W.2d 426, 430 (Minn. 1989) (citation omitted). “[W]e view the evidence in the light most favorable to the verdict” and assume “the jury believed the state’s witnesses and disbelieved any evidence to the contrary.” State v. Hayes, 831 N.W.2d 546, 552 (Minn. 2013) (quotation omitted).

2017See State v. Kramer, 668 N.W.2d 32, 37 (Minn. App. 2003) (stating that question of whether affirmative defense of mistake of age was proved by a preponderance of the evidence “is akin to a challenge to the sufficiency of the evidence”), review denied (Minn. Nov. 18, 2003). 4 Our review “is limited to a painstaking analysis of the record to determine whether the evidence, when viewed in the light most favorable to the verdict, is sufficient to allow the jurors to reach the verdict that they did.” State v. Caldwell, 803 N.W.2d 373, 384 (Minn. 2011).

2016A conviction based on circumstantial evidence receives heightened scrutiny.3 State v. Pratt, 813 N.W.2d 868, 874 (Minn. 2012).

2016Appellate courts “assum[e] that the fact-finder disbelieved any evidence that conflicted with the verdict.” State v. Barshaw, 879 N.W.2d 356, 363 (Minn. 2016).