People v. Bleakley, 69 N.Y.2d 490 (1987)
When reviewing the legal sufficiency of evidence in a criminal case, an appellate court must determine whether any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt, viewing the evidence in the light most favorable to the prosecution.
Summary
The People appealed after the Appellate Term reversed the defendant’s conviction for driving while impaired (DWI), stating the evidence was insufficient. The Court of Appeals held that the Appellate Term applied the wrong standard of review. The proper standard is whether any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt, viewing the evidence in the light most favorable to the prosecution. Because the evidence was legally sufficient under this standard, the Court of Appeals reversed and remitted the case to the Appellate Term for further review.
Facts
The defendant was convicted in Town Court of operating a motor vehicle while his ability was impaired by alcohol. The Town Court found the defendant’s testimony not credible and credited the police testimony.
Procedural History
The Town Court convicted the defendant. The Appellate Term reversed the conviction, stating that the defendant’s guilt was not established beyond a reasonable doubt and dismissed the charges. The People were granted leave to appeal to the New York Court of Appeals.
Issue(s)
Whether the Appellate Term applied the correct standard when reviewing the legal sufficiency of the evidence to support the defendant’s conviction for driving while impaired.
Holding
No, because the Appellate Term should have determined 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.
Court’s Reasoning
The Court of Appeals emphasized that the Appellate Term’s role was to assess whether inferences of guilt could be rationally drawn from the proven facts, not to substitute its own fact-finding for that of the trial court. The Court cited People v. Contes, 60 N.Y.2d 620, 621, quoting Jackson v. Virginia, 443 U.S. 307, 319, reiterating that the standard for appellate review of legal sufficiency is 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’ ” (emphasis in original). The court stated that the Appellate Term “manifestly applied the wrong standard of review.” Applying the correct standard, the Court of Appeals concluded that the evidence was legally sufficient to support the defendant’s conviction. This case clarifies the division of labor between trial courts (as fact-finders) and appellate courts (as reviewers of legal sufficiency). The appellate court’s job is not to re-weigh the evidence and determine guilt or innocence anew, but to assess whether the factfinder’s conclusion was rationally possible based on the evidence presented. The court also cited People v. Geraci, 85 N.Y.2d 359, 371-372 and People v. Norman, 85 N.Y.2d 609, 620-621.