sufficiency of evidence standard in Delaware

2017Generally, we review a sufficiency of evidence claim de novo to determine whether any rational trier of fact, viewing the evidence in the light most favorable to the State, could have found the defendant guilty beyond a reasonable doubt.3 Terry did not move for a directed verdict orjudgment of acquittal so we review this claim 4 “[P]lain error is limited to material defects which are apparent for plain error. on the face of the record; Which are basic, serious and hindamental in their character, and which clearly deprive an accused of a substantial right, or which clearly show manifest injusti

2017Mize also notes that both the 911 caller and Corporal Venero testified that they could not see who was driving the truck. (22) When reviewing a sufficiency of evidence claim, the Court will determine whether, viewing the evidence in the light most favorable to the State, a jury could have found the defendant guilty beyond a reasonable doubt.10 Because the jury is the sole trier of fact responsible for determining witness credibility, resolving any conflicts in the testimony, and drawing all reasonable inferences from 8 Desmond v. State, 654 A.2d 821, 829 (Del. 1994). 9 Milligan v. State, 116 A

2023It is equally possible that the jury, convinced of guilt, properly reached its conclusion on the compound offense, and then through mistake, compromise, or lenity, arrived at an inconsistent conclusion on the lesser offense.11 The Delaware Supreme Court adopted the rule of jury lenity, and Powell’s rationale for it, in 1986 in Tilden v. State.12 The Tilden Court further held “that the controlling standard for testing a claim of inconsistent verdicts is the rule of jury lenity now approved coupled with the sufficiency of evidence standard.”13 In other words, an inconsistent verdict typically ca

2021Compare Tilden, 513 A.2d at 1307 (“[T]he controlling standard for testing a claim of inconsistent verdicts is the rule of lenity . . . coupled with the sufficiency of evidence standard.”), with Priest, 879 A.2d at 586–87 (“[A] multiple-count verdict that includes . . . a compound offense, even if factually inconsistent, must stand where the verdict reflects jury lenity and where the jury has convicted on a [predicate] felony.”), and Priest, 879 A.2d at 589 (“Given the statutory limitation on judicial review, the acquittal [of the predicate felony] removed from the jury’s consideration the very

2021Compare Tilden, 513 A.2d at 1307 (“[T]he controlling standard for testing a claim of inconsistent verdicts is the rule of lenity . . . coupled with the sufficiency of evidence standard.”), with Priest, 879 A.2d at 586–87 (“[A] multiple-count verdict that includes . . . a compound offense, even if factually inconsistent, must stand where the verdict reflects jury lenity and where the jury has convicted on a [predicate] felony.”), and Priest, 879 A.2d at 589 (“Given the statutory limitation on judicial review, the acquittal [of the predicate felony] removed from the jury’s consideration the very

2017We agree with both of these conclusions and therefore affirm. (3) This Court reviews the trial court’s denial of a motion for a new trial for an abuse of discretion.2 (4) In Tilden v. State,3 we held that inconsistency alone is an insufficient basis for challenging a jury verdict and that “the controlling standard for testing a claim of inconsistent verdicts is the rule of jury lenity . . . coupled with the sufficiency of evidence standard.”4 Citing the United States Supreme Court’s opinion in United States v. Powell,5 we also held in Tilden that “[i]f the inconsistency can be explained in ter

2023It is equally possible that the jury, convinced of guilt, properly reached its conclusion on the compound offense, and then through mistake, compromise, or lenity, arrived at an inconsistent conclusion on the lesser offense.11 The Delaware Supreme Court adopted the rule of jury lenity, and Powell’s rationale for it, in 1986 in Tilden v. State.12 The Tilden Court further held “that the controlling standard for testing a claim of inconsistent verdicts is the rule of jury lenity now approved coupled with the sufficiency of evidence standard.”13 In other words, an inconsistent verdict typically ca

2019And he further argues that the State could not prove beyond a reasonable doubt that he possessed any of the contraband seized from the condominium unit because, as was proven at trial, other people also lived in the unit. (10) We review a sufficiency of evidence claim de novo, to determine “whether the evidence, viewed in the light most favorable to the State, was sufficient for a rational trier of fact to have found the essential elements of the crime beyond a reasonable doubt.”6 For the purposes of this inquiry, we do not distinguish between direct and circumstantial evidence.7 Also, we reco

2019See also Williams v. State, 539 A.2d 164, 166-69 (Del. 1988) (discussing the development of Delaware’s sufficiency-of-evidence standard and adoption ofJackson standard), cert. denied, 488 U.S. 969 (1988) ; see also Vincent v. State, 996 A.2d 777, 779 (Del. 2010) (instructing that under this standard: “Although we might not independently have found this evidence sufficient at trial, that question does not arise here.

2019And he further argues that the State could not prove beyond a reasonable doubt that he possessed any of the contraband seized from the condominium unit because, as was proven at trial, other people also lived in the unit. (10) We review a sufficiency of evidence claim de novo, to determine “whether the evidence, viewed in the light most favorable to the State, was sufficient for a rational trier of fact to have found the essential elements of the crime beyond a reasonable doubt.”6 For the purposes of this inquiry, we do not distinguish between direct and circumstantial evidence.7 Also, we reco

2019See also Williams v. State, 539 A.2d 164, 166-69 (Del. 1988) (discussing the development of Delaware’s sufficiency-of-evidence standard and adoption ofJackson standard), cert. denied, 488 U.S. 969 (1988) ; see also Vincent v. State, 996 A.2d 777, 779 (Del. 2010) (instructing that under this standard: “Although we might not independently have found this evidence sufficient at trial, that question does not arise here.

2019And he further argues that the State could not prove beyond a reasonable doubt that he possessed any of the contraband seized from the condominium unit because, as was proven at trial, other people also lived in the unit. (10) We review a sufficiency of evidence claim de novo, to determine “whether the evidence, viewed in the light most favorable to the State, was sufficient for a rational trier of fact to have found the essential elements of the crime beyond a reasonable doubt.”6 For the purposes of this inquiry, we do not distinguish between direct and circumstantial evidence.7 Also, we reco

2019See also Williams v. State, 539 A.2d 164, 166-69 (Del. 1988) (discussing the development of Delaware’s sufficiency-of-evidence standard and adoption ofJackson standard), cert. denied, 488 U.S. 969 (1988) ; see also Vincent v. State, 996 A.2d 777, 779 (Del. 2010) (instructing that under this standard: “Although we might not independently have found this evidence sufficient at trial, that question does not arise here.

2017See also Chao v. State, 604 A.2d 1351, 1363 (Del. 1992); Vouras, 452 A.2d, at 1169 . 21 Byrne Mot. at 3_4. 22 See supra note 6.

2017We agree with both of these conclusions and therefore affirm. (3) This Court reviews the trial court’s denial of a motion for a new trial for an abuse of discretion.2 (4) In Tilden v. State,3 we held that inconsistency alone is an insufficient basis for challenging a jury verdict and that “the controlling standard for testing a claim of inconsistent verdicts is the rule of jury lenity . . . coupled with the sufficiency of evidence standard.”4 Citing the United States Supreme Court’s opinion in United States v. Powell,5 we also held in Tilden that “[i]f the inconsistency can be explained in ter

2017Ct. R. 8; chm v. Smfe, 820 A.2d 342, 358 (Del. 2003). 5 Wainwright v. Stare, 504 A.2d 1096, 1100 (Del. 1986). person by means of a deadly weapon.6 A conviction for PDWDCF requires proof that a defendant possessed a deadly weapon during the commission of a felony.7 A conviction for PDWBPP requires proof that the defendant is a prohibited person and that he knowingly “possesses, purchases, owns or controls a deadly weapon or ammunition or a firearrn.”8 A deadly weapon includes a “knife of any sort (other than an ordinary pocketknife carried in a closed position).”9 (12) There is no plain error h

2017Mize also notes that both the 911 caller and Corporal Venero testified that they could not see who was driving the truck. (22) When reviewing a sufficiency of evidence claim, the Court will determine whether, viewing the evidence in the light most favorable to the State, a jury could have found the defendant guilty beyond a reasonable doubt.10 Because the jury is the sole trier of fact responsible for determining witness credibility, resolving any conflicts in the testimony, and drawing all reasonable inferences from 8 Desmond v. State, 654 A.2d 821, 829 (Del. 1994). 9 Milligan v. State, 116 A

2017Ct. R. 8; chm v. Smfe, 820 A.2d 342, 358 (Del. 2003). 5 Wainwright v. Stare, 504 A.2d 1096, 1100 (Del. 1986). person by means of a deadly weapon.6 A conviction for PDWDCF requires proof that a defendant possessed a deadly weapon during the commission of a felony.7 A conviction for PDWBPP requires proof that the defendant is a prohibited person and that he knowingly “possesses, purchases, owns or controls a deadly weapon or ammunition or a firearrn.”8 A deadly weapon includes a “knife of any sort (other than an ordinary pocketknife carried in a closed position).”9 (12) There is no plain error h

2017Mize also notes that both the 911 caller and Corporal Venero testified that they could not see who was driving the truck. (22) When reviewing a sufficiency of evidence claim, the Court will determine whether, viewing the evidence in the light most favorable to the State, a jury could have found the defendant guilty beyond a reasonable doubt.10 Because the jury is the sole trier of fact responsible for determining witness credibility, resolving any conflicts in the testimony, and drawing all reasonable inferences from 8 Desmond v. State, 654 A.2d 821, 829 (Del. 1994). 9 Milligan v. State, 116 A

1993Levitt v. Bouvier, Del.Supr., 287 A.2d 671, 673 (1972); Smith v. Van Gorkom, Del.Supr., 488 A.2d 858, 871 (1985).

1993Levitt v. Bouvier, Del.Supr., 287 A.2d 671, 673 (1972); Smith v. Van Gorkom, Del.Supr., 488 A.2d 858, 871 (1985).