State v. West
226 Ariz. 559
| Ariz. | 2011Background
- Westes charged with child abuse after infant in their foster care died from severe head trauma.
- Joint trial; both moved for judgment of acquittal under Rule 20(a) at close of State’s case and after evidence; motions denied.
- Jury convicted Randall of reckless child abuse not likely to produce death or serious injury and Penny of negligent child abuse likely to produce death or serious injury.
- Post-trial Rule 20(b) renewals granted; trial court concluded lack of substantial evidence to show which defendant caused the injury or permitted it.
- Court of Appeals reversed, treating the trial court’s ruling as improper re-determination of the quantum of evidence under Hyder.
- Arizona Supreme Court overrules Hyder to align Rule 20(a) and 20(b) standards; remands for sufficiency of evidence review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 20(a) and 20(b) use the same standard. | West argues Hyder’s separate standard controls post-verdict motions. | West contends Hyder retains distinct post-verdict criteria. | Yes; same standard applies to pre- and post-verdict motions. |
| Whether Hyder should be disapproved. | State adheres to Hyder’s approach. | Court should abandon Hyder’s limitations. | Hyder disapproved; standard unified. |
| What is the governing standard for substantial evidence on Rule 20 motions? | Record must show substantial evidence supporting conviction. | Court may reweigh evidence only if necessary. | Substantial evidence standard; de novo review on appeal. |
| Who reviews the sufficiency of the evidence after a post-verdict acquittal grant? | Appellate review determines sufficiency. | Trial court’s rationale suffices if evidence exists. | Remand to determine sufficiency and merits under Rule 20(b). |
Key Cases Cited
- Hyder v. Superior Court, 128 Ariz. 216 (1981) (previous rule-based limit on post-verdict judgments of acquittal)
- State v. Bible, 175 Ariz. 549 (1993) (de novo review of Rule 20 motions; evidence viewed most favorably to government)
- State v. Mathers, 165 Ariz. 64 (1990) (settles standard for substantial evidence; jury standard from Jackson v. Virginia)
- Jackson v. Virginia, 443 U.S. 307 (1979) (reasonable doubt framework for sufficiency of evidence)
- State v. Lee, 189 Ariz. 590 (1997) (no judicial re-weighing of facts when reasonable minds differ)
- State v. Davolt, 207 Ariz. 191 (2004) (limits on weighing in Rule 20 motions; consistency with substantial-evidence analysis)
- State v. Bible, 858 P.2d 1152 (1993) ((see above))