Miles Guo Court Documents · Doc 467

摘要

Government Opposition · Rule 29(c) Motion for Acquittal

This two-page letter, dated September 19, 2024 from the Assistant U.S. Attorneys, opposes Mr. Guo's August 29, 2024 motion (Dkt. 464, case-doc-464) for a judgment of acquittal under Federal Rule of Criminal Procedure 29(c) in United States v. Miles Guo, S3 23 Cr. 118 (AT).

Legal Standard Recited

• To prevail on an insufficiency-of-the-evidence claim under Rule 29, a defendant bears the "heavy burden" of showing that "no rational trier of fact could have found all of the elements of the crime beyond a reasonable doubt" (citing United States v. Caracappa, 614 F.3d 30, 43 (2d Cir. 2010));
• The same heavy burden is reaffirmed in United States v. Jackson, 335 F.3d 170, 180 (2d Cir. 2003);
• The jury's verdict must be upheld if "any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt" (citing Jackson v. Virginia, 443 U.S. 307, 319 (1979)).

Government's Position

When evaluating a Rule 29 motion, the Court should:

• Review all of the evidence presented;
• View the evidence in the light most favorable to the government;
• Credit every reasonable inference in the government's favor;
• Defer to the jury's assessment of witness credibility and weight of the evidence.

Applying this framework, the government argues the trial record amply supports the jury's verdict on each of the nine counts of conviction.