Rule 1: The court reviews allegations of insufficient evidence in the following manner: The relevant inquiry when reviewing claims of insufficient evidence 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. Circumstantial evidence and direct evidence are accorded the same weight and the uncorroborated testimony of an accomplice may support a conviction under federal law. Therefore, the court will reverse a judgment for insufficiency of evidence only if, viewing the record as a whole, the judgment is not supported by substantial and competent evidence.
Rule 2: Neither Brady nor the Federal Rules of Criminal Procedure mandate that a trial court produce a copy of a presentence report concerning a government witness, prepared for the court, to the defense upon request. Nor do they require a trial court to review such a report in camera for potential Brady material.
Defendants were charged with conspiracy to commit arson in violation of 18 U.S.C.S. § 844(i), arson with personal injuries in violation of 18 U.S.C.S. §§ 844(i) and 2, and perjury in violation of 18 U.S.C.S. § 1623. At trial, the court denied defendant’s request for a copy of a government witness’ presentence report as well as the request to look at the report in camera. The trial court convicted defendants. On appeal, the appellate court affirmed defendants' convictions.
Issue 1: Were defendants’ convictions based on insufficient evidence?
Issue 2: Did the trial court abuse its discretion when it denied defendant’s request for access to a presentence report and for a review of such a report in camera?
Answer 1: No; Answer 2: No
Conclusion 1: The convictions were supported by substantial and competent evidence such that a rational trier of fact could have found the essential elements of each crime charged beyond a reasonable doubt.
Conclusion 2: The trial court did not abuse its discretion in denying defendant's request.