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Name: People v. Adair
Case #: S098218
Court: CA Supreme Court
District CalSup
Opinion Date: 01/30/2003
Subsequent History: None

Appellant was acquitted of murdering her husband, and petitioned the trial court pursuant to Penal Code section 851.8, subdivision (e) for a finding of factual innocence. The trial court granted the motion, and the prosecutor appealed. The Court of Appeal reversed the trial court’s decision, applying a de novo standard of review, and disagreeing with the substantial evidence test applied in People v. Scott M. and People v. Pogre. Independently examining the record, the Court of Appeal concluded that the defendant failed to meet her burden of establishing that no reasonable cause exists to believe she committed the murder. The Supreme Court granted appellant’s petition for review to resolve the conflict among the Courts of Appeal regarding the appropriate standard of review. The Supreme Court held that although the appellate court should defer to the trial court’s factual findings to the extent that they are supported by substantial evidence, it must independently examine the record to determine whether the defendant has established that no reasonable cause exists to believe he committed the charged offense (agreeing with Scott M. and Pogre.) Here, appellant did not meet that burden. One reasonable interpretation of the evidence suggested strongly that appellant bludgeoned her husband to death, and had personal and financial motivation to do so.