The applicable standard for conviction of a crime 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.
The woman and a friend were drinking in a bar. A man approached the victim and they talked. When the woman decided to leave, the man asked for a ride home and she agreed to drive him home. Afterwards, the man took the woman's car keys and would not return them until after they had intercourse. The woman stated that she feared the look in the man's eyes and that he choked her lightly when she protested having intercourse. After intercourse, he returned her keys and she left. The man was convicted of rape in the second degree. On appeal to the Court of Special Appeals, Criminal Court of Baltimore (Maryland) reversed his conviction finding that the evidence was legally insufficient to warrant a conclusion that the man's words or actions created a reasonable fear in the woman's mind that he would have harmed her. The case was appealed to the Court of Appeals of Maryland.
Was the conviction proper?
The court found that, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of rape in the second degree beyond a reasonable doubt. The reasonableness of the victim's fear was a question for the jury to resolve. A rationale jury could have found that the victim was in fear and so did not consent to the intercourse and that defendant's conduct was reasonably calculated to induce fear in the victim such that there was force. The court determined that the appellate court substituted its judgment for that of the jury instead of applying an appropriate standard of review.