Standard of review for convictions based on circumstantial evidence

Contrary to what a portion of the public believes, circumstantial evidence is admissible and can be used to prove a party’s case.  When circumstantial evidence forms the basis for a conviction, a reviewing court will engage in a two-part analysis in addressing the sufficiency of the circumstantial evidence.  The components of this analysis were reviewed recently by the Minnesota Supreme Court, State v. Hurd, A11-1057 (Minn. August 8, 2012), and by the Minnesota Court of Appeals in an unpublished opinion, State v. Wright, A11-2002 (Minn. App. September 17, 2012).

When a court is asked to review the sufficiency of evidence to support a criminal conviction, it must determine whether the evidence, when viewed in the light most favorable to the verdict, was sufficient to allow a jury to return a guilty verdict. State v. Fleck, 777 N.W.2d 233, 236 (Minn. 2010).  Credibility determinations are for the jury, and the court assumes that the jury disbelieved any evidence contrary to the verdict.  Id.  On review, the court analyzes whether the facts in the record and the legitimate inferences drawn from them would permit the jury to reasonably conclude that the defendant was guilty beyond a reasonable doubt on the charges presented. Id.

In analyzing the sufficiency of circumstantial evidence, first a court will identify the circumstances proved, viewing the evidence in the light most favorable to the verdict. State v. Andersen, 784 N.W.2d 320, 329 (Minn. 2010).  Next, the court examines the reasonableness of inferences that can be drawn from the circumstantial evidence, including inferences of both innocence and guilt. Id. To sustain a conviction, all rational inferences must be consistent with guilt and inconsistent with innocence. Id. at 330.

Applying this analysis, in State v. Hurd, the Minnesota Supreme Court considered the evidence of premeditation related to what the appellant had admitted was an intentional killing. The court addressed three categories of evidence related to premeditation: planning activity, motive, and nature of the killing. The court noted 17 main facts that it ascertained from the record with respect to the appellant’s planning activity.  The facts included details of the appellant’s conduct prior to the killing, during the killing, and after the killing. After reviewing those 17 facts, the Hurd Court found that the inferences to be drawn from the circumstances proved were consistent with a finding of premeditation and inconsistent with any other conclusion.

The court followed the same process in reviewing the circumstances showing motive and the nature of the killing.  The court then found that the reasonable inferences to be drawn from the evidence in each of the three categories were consistent with premeditation and inconsistent with any other conclusion.  As such, the court found that the evidence of premeditation, although circumstantial, was sufficient to support the conviction for first degree murder.