sufficiency of the evidence standard (District of Columbia) · Go Syfert
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sufficiency of the evidence standard in District of Columbia

14 District of Columbia opinions name it 1 courts 1992–2025 4 in the last five years

The cases below were cited by District of Columbia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
Lewis v. United Statesgreen
dc · 2001 · cited in 2 District of Columbia opinions naming this issue, 2009–2009
2 sentences

2009“The evidence must support an inference, rather than mere speculation, as to each element of an offense.” Lewis v. United States, 767 A.2d 219, 222 (D.C.2001).

2009"The evidence must support an inference, rather than mere speculation, as to each element of an offense." Lewis v. United States, 767 A.2d 219, 222 (D.C.2001).

22
Earle v. United Statesgreen
dc · 1992 · cited in 2 District of Columbia opinions naming this issue, 2009–2009
2 sentences

2009The Evidence Was Not Sufficient to Convict L.L. of First Degree Child Sex Abuse In an attempt to prevent the government from retrying him for first degree child sexual abuse, L.L. argues that the evidence was “insufficient to prove beyond a reasonable doubt the essential element of penetration.” 4 When reviewing a sufficiency of the evidence claim, “we must view all the evidence in the light most favorable to the government and give deference to the right of the [fact finder] to weigh the evidence, determine the credibility of the witnesses, and draw all justifiable inferences of fact, making

2009The Evidence Was Not Sufficient to Convict L.L. of First Degree Child Sex Abuse In an attempt to prevent the government from retrying him for first degree child sexual abuse, L.L. argues that the evidence was "insufficient to prove beyond a reasonable doubt the essential element of penetration." [4] When reviewing a sufficiency of the evidence claim, "we must view all the evidence in the light most favorable to the government and give deference to the right of the [fact finder] to weigh the evidence, determine the credibility of the witnesses, and draw all justifiable inferences of fact, makin

22
Curry v. United Statesgreen
dc · 1987 · cited in 2 District of Columbia opinions naming this issue, 1992–2002
2 sentences

2002Curry v. United States, 520 A.2d 255, 263 (D.C.1987) (citation omitted).

1992See Curry v. United States, 520 A.2d 255, 263 (D.C.1987) (whether “a reasonable juror must have a reasonable doubt as to the existence of any of the essential elements of the crime” (emphasis in original) (citation omitted)); Ray v. United States, 575 A.2d 1196, 1198 (D.C.1990) (assault consists of (1) an attempt or threat by defendant to injure victim, (2) defendant’s apparent ability to injure victim and (3) defendant’s intent to do act constituting assault); Super.Ct.Crim.R. 29.

22
United States v. Richard Beckgreen
ca7 · 1980 · cited in 1 District of Columbia opinions naming this issue, 2025–2025
1 sentence

2025Schools v. United States, 84 A.3d 503, 508 (D.C. 2013) (“The standard is not so strict that the defendant’s evidence must be disregarded.” (quoting United States v. Beck, 615 F.2d 441, 448 (7th Cir. 1980))).

11
James M. Schools v. United Statesgreen
dc · 2013 · cited in 1 District of Columbia opinions naming this issue, 2025–2025
1 sentence

2025Schools v. United States, 84 A.3d 503, 508 (D.C. 2013) (“The standard is not so strict that the defendant’s evidence must be disregarded.” (quoting United States v. Beck, 615 F.2d 441, 448 (7th Cir. 1980))).

11
Dickerson v. United Statesgreen
dc · 1994 · cited in 1 District of Columbia opinions naming this issue, 2024–2024
1 sentence

2024Since the court is vacating that conviction on other grounds, we need not consider his jury coercion argument. 46 credibility of the witnesses and to draw reasonable inferences from the testimony.” Dickerson v. United States, 650 A.2d 680, 683 (D.C. 1994).

11
State v. Williamsgreen
conn · 1987 · cited in 1 District of Columbia opinions naming this issue, 2016–2016
2 sentences

2016See Hoffa v. United States, 385 U.S. 293, 310 (1966) (“[T]he minimum evidence to establish probable cause . . . may fall far short of the amount necessary to support a criminal conviction.”); see also Paret-Ruiz v. United States, 827 F.3d 167, 179 (1st Cir. 2016) (explaining that the sufficiency of the evidence standard requires “a higher degree of certainty than the probable cause standard”); State v. Suddith, 842 A.2d 716, 726 (Md. 2004); Commonwealth v. Collado, 690 N.E.2d 424 , 428 n.8 (Mass. 1998); State v. Williams, 534 A.2d 230, 240 (Conn. 1987); State v. Hussong, 739 N.W.2d 922, 928 (M

2016See Hoffa v. United States, 385 U.S. 293, 310 , 87 S.Ct. 408 , 17 L.Ed.2d 374 (1966) (“[T]he minimum evidence to establish probable cause ... may fall far short of the amount necessary to support a criminal conviction.”); see also Paret-Ruiz v. United States, 827 F.3d 167, 179 (1st Cir. 2016) (explaining that the sufficiency of the evidence standard requires “a higher degree of certainty than the probable cause standard”); State v. Suddith, 379 Md. 425 , 842 A.2d 716, 726 (2004); Commonwealth v. Collado, 426 Mass. 675 , 690 N.E.2d 424 , 428 n.8 (1998); State v. Williams, 205 Conn. 456 , 534 A.

11
Hoffa v. United Statesgreen
scotus · 1966 · cited in 1 District of Columbia opinions naming this issue, 2016–2016
2 sentences

2016See Hoffa v. United States, 385 U.S. 293, 310 (1966) (“[T]he minimum evidence to establish probable cause . . . may fall far short of the amount necessary to support a criminal conviction.”); see also Paret-Ruiz v. United States, 827 F.3d 167, 179 (1st Cir. 2016) (explaining that the sufficiency of the evidence standard requires “a higher degree of certainty than the probable cause standard”); State v. Suddith, 842 A.2d 716, 726 (Md. 2004); Commonwealth v. Collado, 690 N.E.2d 424 , 428 n.8 (Mass. 1998); State v. Williams, 534 A.2d 230, 240 (Conn. 1987); State v. Hussong, 739 N.W.2d 922, 928 (M

2016See Hoffa v. United States, 385 U.S. 293, 310 , 87 S.Ct. 408 , 17 L.Ed.2d 374 (1966) (“[T]he minimum evidence to establish probable cause ... may fall far short of the amount necessary to support a criminal conviction.”); see also Paret-Ruiz v. United States, 827 F.3d 167, 179 (1st Cir. 2016) (explaining that the sufficiency of the evidence standard requires “a higher degree of certainty than the probable cause standard”); State v. Suddith, 379 Md. 425 , 842 A.2d 716, 726 (2004); Commonwealth v. Collado, 426 Mass. 675 , 690 N.E.2d 424 , 428 n.8 (1998); State v. Williams, 205 Conn. 456 , 534 A.

11
State v. Suddithgreen
md · 2004 · cited in 1 District of Columbia opinions naming this issue, 2016–2016
2 sentences

2016See Hoffa v. United States, 385 U.S. 293, 310 (1966) (“[T]he minimum evidence to establish probable cause . . . may fall far short of the amount necessary to support a criminal conviction.”); see also Paret-Ruiz v. United States, 827 F.3d 167, 179 (1st Cir. 2016) (explaining that the sufficiency of the evidence standard requires “a higher degree of certainty than the probable cause standard”); State v. Suddith, 842 A.2d 716, 726 (Md. 2004); Commonwealth v. Collado, 690 N.E.2d 424 , 428 n.8 (Mass. 1998); State v. Williams, 534 A.2d 230, 240 (Conn. 1987); State v. Hussong, 739 N.W.2d 922, 928 (M

2016See Hoffa v. United States, 385 U.S. 293, 310 , 87 S.Ct. 408 , 17 L.Ed.2d 374 (1966) (“[T]he minimum evidence to establish probable cause ... may fall far short of the amount necessary to support a criminal conviction.”); see also Paret-Ruiz v. United States, 827 F.3d 167, 179 (1st Cir. 2016) (explaining that the sufficiency of the evidence standard requires “a higher degree of certainty than the probable cause standard”); State v. Suddith, 379 Md. 425 , 842 A.2d 716, 726 (2004); Commonwealth v. Collado, 426 Mass. 675 , 690 N.E.2d 424 , 428 n.8 (1998); State v. Williams, 205 Conn. 456 , 534 A.

11
State v. Hussonggreen
minnctapp · 2007 · cited in 1 District of Columbia opinions naming this issue, 2016–2016
2 sentences

2016See Hoffa v. United States, 385 U.S. 293, 310 (1966) (“[T]he minimum evidence to establish probable cause . . . may fall far short of the amount necessary to support a criminal conviction.”); see also Paret-Ruiz v. United States, 827 F.3d 167, 179 (1st Cir. 2016) (explaining that the sufficiency of the evidence standard requires “a higher degree of certainty than the probable cause standard”); State v. Suddith, 842 A.2d 716, 726 (Md. 2004); Commonwealth v. Collado, 690 N.E.2d 424 , 428 n.8 (Mass. 1998); State v. Williams, 534 A.2d 230, 240 (Conn. 1987); State v. Hussong, 739 N.W.2d 922, 928 (M

2016See Hoffa v. United States, 385 U.S. 293, 310 , 87 S.Ct. 408 , 17 L.Ed.2d 374 (1966) (“[T]he minimum evidence to establish probable cause ... may fall far short of the amount necessary to support a criminal conviction.”); see also Paret-Ruiz v. United States, 827 F.3d 167, 179 (1st Cir. 2016) (explaining that the sufficiency of the evidence standard requires “a higher degree of certainty than the probable cause standard”); State v. Suddith, 379 Md. 425 , 842 A.2d 716, 726 (2004); Commonwealth v. Collado, 426 Mass. 675 , 690 N.E.2d 424 , 428 n.8 (1998); State v. Williams, 205 Conn. 456 , 534 A.

11
Paret-Ruiz v. United Statesgreen
ca1 · 2016 · cited in 1 District of Columbia opinions naming this issue, 2016–2016
2 sentences

2016See Hoffa v. United States, 385 U.S. 293, 310 (1966) (“[T]he minimum evidence to establish probable cause . . . may fall far short of the amount necessary to support a criminal conviction.”); see also Paret-Ruiz v. United States, 827 F.3d 167, 179 (1st Cir. 2016) (explaining that the sufficiency of the evidence standard requires “a higher degree of certainty than the probable cause standard”); State v. Suddith, 842 A.2d 716, 726 (Md. 2004); Commonwealth v. Collado, 690 N.E.2d 424 , 428 n.8 (Mass. 1998); State v. Williams, 534 A.2d 230, 240 (Conn. 1987); State v. Hussong, 739 N.W.2d 922, 928 (M

2016See Hoffa v. United States, 385 U.S. 293, 310 , 87 S.Ct. 408 , 17 L.Ed.2d 374 (1966) (“[T]he minimum evidence to establish probable cause ... may fall far short of the amount necessary to support a criminal conviction.”); see also Paret-Ruiz v. United States, 827 F.3d 167, 179 (1st Cir. 2016) (explaining that the sufficiency of the evidence standard requires “a higher degree of certainty than the probable cause standard”); State v. Suddith, 379 Md. 425 , 842 A.2d 716, 726 (2004); Commonwealth v. Collado, 426 Mass. 675 , 690 N.E.2d 424 , 428 n.8 (1998); State v. Williams, 205 Conn. 456 , 534 A.

11
In Re SGgreen
dc · 1990 · cited in 1 District of Columbia opinions naming this issue, 2011–2011
1 sentence

2011In reviewing a sufficiency of the evidence claim, “we must consider the evidence in the light most favorable to the government, giving full play to the right of the judge, as the trier of fact, to determine credibility, weigh the evidence, and draw reasonable inference.” In re S.G., 581 A.2d 771, 774 (D.C.1990).

11
Landise v. Maurogreen
dc · 1998 · cited in 1 District of Columbia opinions naming this issue, 2003–2003
1 sentence

2003Ms. Cook contends that the trial court erred in failing to grant her motion “for judgment as a matter of law on the drug haven claim.” She maintains that “no facts were alleged or proven to establish any of the [RDEA’s] seven elements.” The landlord argues that ample evidence was presented to allow the case to go to the jury and that “the presence] of any one of the [statutory factors] enumerated in § 45-2559(a) [§ 42-3602(a)] is *945 sufficient to find that the rental unit is a drug haven.” “We review [a denial of] motions for judgment as a matter of law de novo." Landise v. Mauro, 725 A.2d 4

11
United States v. Richard Paul Spinner, IIIgreen
cadc · 1998 · cited in 1 District of Columbia opinions naming this issue, 2002–2002
2 sentences

2002Circuit "review[s] an appellant’s sufficiency-of-the-evidence challenge for plain error when a motion for judgment of acquittal was based on specific (and different) grounds.” United States v. Spinner, 332 U.S.App.D.C. 1, 6 , 152 F.3d 950, 955 (1998) (citation omitted).

2002Circuit "review[s] an appellant’s sufficiency-of-the-evidence challenge for plain error when a motion for judgment of acquittal was based on specific (and different) grounds.” United States v. Spinner, 332 U.S.App.D.C. 1, 6 , 152 F.3d 950, 955 (1998) (citation omitted).

11
Ray v. United Statesgreen
dc · 1990 · cited in 1 District of Columbia opinions naming this issue, 1992–1992
1 sentence

1992See Curry v. United States, 520 A.2d 255, 263 (D.C.1987) (whether “a reasonable juror must have a reasonable doubt as to the existence of any of the essential elements of the crime” (emphasis in original) (citation omitted)); Ray v. United States, 575 A.2d 1196, 1198 (D.C.1990) (assault consists of (1) an attempt or threat by defendant to injure victim, (2) defendant’s apparent ability to injure victim and (3) defendant’s intent to do act constituting assault); Super.Ct.Crim.R. 29.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in District of Columbia. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
Patrick F. Andrews v. United States green
dc · 2018
2 sentences

2025Andrews, 179 A.3d at 287 (citing Kyles, 514 U.S. at 434 ).

2025Andrews, 179 A.3d at 287 (citing Kyles, 514 U.S. at 434 ).

22025–2025
Kyles v. Whitley green
scotus · 1995
2 sentences

2025Andrews, 179 A.3d at 287 (citing Kyles, 514 U.S. at 434 ).

2025Andrews, 179 A.3d at 287 (citing Kyles, 514 U.S. at 434 ).

22025–2025
State v. Richardson (Slip Opinion) green
ohio · 2016
2 sentences

2020State v. Richardson, 150 Ohio St.3d 554 , 2016-Ohio-8448, ¶ 13 .

2020State v. Richardson, 150 Ohio St.3d 554 , 2016-Ohio-8448, ¶ 13 .

12020–2020
State v. Beverly (Slip Opinion) green
ohio · 2015
2 sentences

2020State v. Beverly, 143 Ohio St.3d 258 , 2015-Ohio-219 , ¶ 15.

2020State v. Beverly, 143 Ohio St.3d 258 , 2015-Ohio-219 , ¶ 15.

12020–2020
Commonwealth v. Collado green
mass · 1998
2 sentences

2016See Hoffa v. United States, 385 U.S. 293, 310 (1966) (“[T]he minimum evidence to establish probable cause . . . may fall far short of the amount necessary to support a criminal conviction.”); see also Paret-Ruiz v. United States, 827 F.3d 167, 179 (1st Cir. 2016) (explaining that the sufficiency of the evidence standard requires “a higher degree of certainty than the probable cause standard”); State v. Suddith, 842 A.2d 716, 726 (Md. 2004); Commonwealth v. Collado, 690 N.E.2d 424 , 428 n.8 (Mass. 1998); State v. Williams, 534 A.2d 230, 240 (Conn. 1987); State v. Hussong, 739 N.W.2d 922, 928 (M

2016See Hoffa v. United States, 385 U.S. 293, 310 , 87 S.Ct. 408 , 17 L.Ed.2d 374 (1966) (“[T]he minimum evidence to establish probable cause ... may fall far short of the amount necessary to support a criminal conviction.”); see also Paret-Ruiz v. United States, 827 F.3d 167, 179 (1st Cir. 2016) (explaining that the sufficiency of the evidence standard requires “a higher degree of certainty than the probable cause standard”); State v. Suddith, 379 Md. 425 , 842 A.2d 716, 726 (2004); Commonwealth v. Collado, 426 Mass. 675 , 690 N.E.2d 424 , 428 n.8 (1998); State v. Williams, 205 Conn. 456 , 534 A.

12016–2016
Jackson v. United States neutral
dc · 2010
1 sentence

2013In Jackson v. United States, 996 A.2d 796 (D.C.2010), we had our only other occasion to review a sufficiency of the evidence claim relating to a conviction for criminal neglect of a vulnerable adult in violation of D.C.Code § 22-934.

12013–2013
Abdulshakur v. District of Columbia green
dc · 1991
1 sentence

2002In Abdulshakur, supra, this court left open whether it would follow this forfeiture rule.

12002–2002

Where else courts name it

OH 1032 (1972–2026) LA 995 (1984–2026) PA 634 (1975–2026) TX 318 (1984–2026) IN 314 (1986–2025) WA 279 (1992–2026) CA 225 (1988–2026) CT 210 (1985–2026) NE 202 (1998–2025) TN 191 (1996–2026) IL 189 (1989–2026) IA 187 (1984–2026) MN 139 (1987–2026) NM 117 (1995–2025) MI 98 (1985–2026) MO 97 (1987–2025) VA 76 (1996–2026) WI 64 (1986–2026) CO 62 (1994–2026) UT 53 (1993–2026) WY 53 (1986–2026) FL 45 (1990–2025) KS 45 (1981–2026) AR 44 (2002–2026) ND 42 (1993–2026) NH 34 (1991–2025) MS 29 (1995–2024) GA 24 (1986–2024) NC 23 (1982–2026) ME 23 (1994–2025) NV 17 (1976–2022) OK 16 (1986–2013) MD 15 (1972–2026) AL 14 (1984–2025) DC 14 (1992–2025) WV 13 (1995–2024) MA 12 (1996–2024) NJ 12 (1996–2026) VT 10 (2013–2021) AZ 9 (2006–2026) GU 9 (2021–2024) MT 8 (1991–2024) ID 8 (2013–2021) HI 7 (2007–2023) DE 7 (2017–2025) VI 6 (2012–2017) OR 4 (2004–2025) SD 4 (2009–2022) KY 4 (2009–2025) SC 3 (2013–2020) AK 3 (2014–2021) RI 2 (2015–2015) NY 2 (2005–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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