A motion for directed verdict of acquittal challenges the sufficiency of the state's evidence state to support a guilty verdict beyond a reasonable doubt. In passing on such a motion, courts give full credibility to the state's evidence, view it in a light most favorable to the state, and draw therefrom every reasonable inference consistent with guilt.
Defendant was convicted of leaving the scene of an accident, death resulting, in violation of R.I. GEN. LAWS § 31-26-1 (1968) and manslaughter following the death of a person struck by defendant's vehicle. After his motions for a new trial were denied, defendant brought bills of exceptions challenging his convictions. The appellate court affirmed his conviction for leaving the scene of an accident but reversed his manslaughter conviction and remanded the action for further proceedings.
Was there reasonable doubt as to defendant’s guilt?
The court held that there remained a reasonable doubt as to defendant's innocence on the manslaughter charge because there was no evidence that defendant possessed the requisite culpable negligence either before or after his vehicle struck the victim. The court also held that the evidence was consistent with the finding of defendant's guilt on the leaving the scene of an accident charge and was not consistent with any other finding.