Judgment of Acquittal, Motion for
Except as indicated, all indented material is copied directly from the opinion.
Decisions of the Tennessee Supreme Court
State v. Weems, 619 S.W.3d 208, 221 (Tenn. 2021).
Under Tennessee law, the trial court applies the same standard of review when examining a motion for judgment of acquittal as does the appellate court when a party challenges the sufficiency of the evidence underlying the jury’s verdict. State v. Carroll, 36 S.W.3d 854, 869 (Tenn. Crim. App. 1999) (citing State v. Ball, 973 S.W.2d 288, 292 (Tenn. Crim. App. 1998)). The inquiry is limited and centers around “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.” State v. Little, 402 S.W.3d 202, 211 (Tenn. 2013) (quoting Jackson v. Virginia, 443 U.S. 307, 319, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979)); see also Tenn. R. App. P. 13(e). Further, all reasonable and legitimate inferences from the evidence must be drawn in favor of the prosecution and all countervailing evidence discarded. See State v. Collier, 411 S.W.3d 886, 893 (Tenn. 2013) (quoting State v. James, 315 S.W.3d 440, 455 (Tenn. 2010)). The trial court, and the reviewing court on appeal, is not to reweigh the evidence or reassess the credibility of the witnesses. State v. Stephens, 521 S.W.3d 718, 724 (Tenn. 2017). The decision to deny or grant a motion for judgment of acquittal is a question of law, which this Court reviews de novo with no presumption of correctness. See Little, 402 S.W.3d at 211.
Decisions of the Tennessee Court of Criminal Appeals
State v. Lampley, No. M2021-00636-CCA-R3-CD, p. 20-21 (Tenn. Ct. Crim. App. Jan. 24, 2023).
In ruling on a motion for judgment of acquittal, the trial court looks at the legal sufficiency of the evidence and does not weigh the evidence. Id. “The standard by which the trial court determines a motion for a judgment of acquittal is, in essence, the same standard that applies on appeal in determining the sufficiency of the evidence after a conviction.” State v. Little, 402 S.W.3d 202, 211 (Tenn. 2013) (citing State v. Ball, 973 S.W.2d 288, 292 (Tenn. Crim. App. 1998); State v. Anderson, 880 S.W.2d 720, 726 (Tenn. Crim. App. 1994)). Because “[t]he standard by which the trial court determines a motion for judgment of acquittal at the end of all the proof, is, in essence, the same standard which applies on appeal in determining the sufficiency of the evidence after a conviction,” we will resolve both Defendant’s challenge to the denial of the motion for judgment of acquittal and sufficiency of the evidence together. State v. Thompson, 88 S.W.3d 611, 614- 15 (Tenn. Crim. App. 2000).
State v. Samuel, No. E2020-01033-CCA-R3-CD, p. 10 (Tenn. Ct. Crim. App. Aug. 26, 2022).
The standard of review for a trial court’s denial of a motion for a judgment of acquittal is the same as the “standard that applies on appeal in determining the sufficiency of the evidence[.]” State v. Little, 402 S.W.3d 202, 211 (Tenn. 2013). When a defendant challenges the sufficiency of the evidence, this Court is obliged to review that claim according to certain well-settled principles. The relevant question is whether any rational trier of fact could have found the accused guilty of every element of the offense beyond a reasonable doubt. See Tenn. R. App. P. 13(e); Jackson v. Virginia, 443 U.S. 307, 319 (1979); State v. Davis, 354 S.W.3d 718, 729 (Tenn. 2011).
Because the jury’s verdict replaces the presumption of innocence with one of guilt, the burden on appeal is shifted onto Defendant to show that the evidence introduced at trial was insufficient to support such a verdict. State v. Reid, 91 S.W.3d 247, 277 (Tenn. 2002). Thus, “‘we afford the prosecution the strongest legitimate view of the evidence as well as all reasonable and legitimate inferences which may be drawn therefrom.’” Davis, 354 S.W.3d at 729 (quoting State v. Majors, 318 S.W.3d 850, 857 (Tenn. 2010)). Questions involving the credibility of witnesses and the weight and value to be given the evidence, as well as all factual disputes raised by the evidence, are resolved by the jury as the trier of fact. State v. Bland, 958 S.W.2d 651, 659 (Tenn. 1997); State v. Pruett, 788 S.W.2d 559, 561 (Tenn. 1990). “A guilty verdict by the jury, approved by the trial court, accredits the testimony of the witnesses for the State and resolves all conflicts in favor of the prosecution’s theory.” Reid, 91 S.W.3d at 277 (quoting Bland, 958 S.W.2d at 659). It is not the role of this Court to reweigh or reevaluate the evidence, nor to substitute our own inferences for those drawn from the evidence by the trier of fact. Id. The standard of review is the same whether the conviction is based upon direct evidence, circumstantial evidence, or a combination of the two. State v. Dorantes, 331 S.W.3d 370, 379 (Tenn. 2011); State v. Hanson, 279 S.W.3d 265, 275 (Tenn. 2009).
State of Tennessee v. Myers, No. E2021-00841-CCA-R3-CD, p. 7-8 (Tenn. Ct. Crim. App. July 22, 2022).
The Defendant also challenges the denial of his motion for judgment of acquittal. “The standard by which the trial court determines a motion for a judgment of acquittal is, in essence, the same standard that applies on appeal in determining the sufficiency of the evidence after a conviction.” State v. Little, 402 S.W.3d 202, 211 (Tenn. 2013). A motion for judgment of acquittal is waived if the defendant introduces proof after making the motion, and the appellate court merely analyzes the sufficiency of all evidence. Finch v. State, 226 S.W.3d 307, 316-17 (Tenn. 2007). In this case, the Defendant introduced proof after the State rested its case, and accordingly, the Defendant’s challenge is simply one to the sufficiency of the evidence. The Defendant also asserts that the court erred by affirming the verdicts as thirteenth juror. See Tenn. R. Crim. P. 33. His argument essentially urges us to conclude that “the jury verdicts were against the weight of the evidence.” However, an appellate court, while it may assess the sufficiency of the evidence, may not reweigh the evidence. State v. Stephens, 521 S.W.3d 718, 727 (Tenn. 2017) (noting that the trial court may reweigh the evidence as thirteenth juror but that“‘[a]ppellate courts are ill-suited … to assess whether the verdict is supported by the weight and credibility of the evidence’” (quoting State v. Moats, 906 S.W.2d 431, 435 (Tenn. 1995))). Accordingly, we analyze the challenges as challenges to the sufficiency of the evidence.
State of Tennessee v. Dawson, No. E2021-00913-CCA-R3-CD, p. 10 (Tenn. Ct. Crim. App. May 18, 2022).
A trial judge may “direct a judgment of acquittal when the evidence is insufficient to warrant a conviction either at the time the [S]tate rests or at the conclusion of all the evidence.” State v. James, 315 S.W.3d 440, 455 (Tenn. 2010) (citations omitted). The standard by which the trial court determines a motion for judgment of acquittal at that time is, in essence, the same standard which applies on appeal in determining the sufficiency of the evidence after a conviction. State v. Ball, 973 S.W.2d 288, 292 (Tenn. Crim. App. 1998); State v. Anderson, 880 S.W.2d 720, 726 (Tenn. Crim. App. 1994). Because the defendant presented no proof at trial, we combine our analysis of the denial of his motion for judgment of acquittal and the sufficiency of the convicting evidence. See generally State v. Thompson, 88 S.W.3d 611, 614-15 (Tenn. Crim. App. 2000).
State of Tennessee v. Benitez, No. M2021-00073-CCA-R3-CD, p. 23 (Tenn. Ct. Crim. App. Apr. 27, 2022).
Because “[t]he standard by which the trial court determines a motion for judgment of acquittal at the end of all the proof, is, in essence, the same standard which applies on appeal in determining the sufficiency of the evidence after a conviction,” we will resolve both Defendant’s challenge to the denial of the motion for judgment of acquittal and sufficiency of the evidence together. State v. Thompson, 88 S.W.3d 611, 614-15 (Tenn. Crim. App. 2000).
