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Name: People v. Adair
Case #: B138462
Court: CA Court of Appeal
District 2 DCA
Division: 3
Opinion Date: 05/09/2001
Subsequent History: Rev. granted 8/22/01 as S098218
Summary

Appellant was acquitted of the special circumstance murder of her husband. She filed a petition pursuant to Penal Code section 851.8, for a finding of factual innocence, which was granted by the trial court. Following an appeal by the prosecutor, the appellate court reversed the trial court’s finding. The appropriate standard of review is to independently review the record to ascertain if any reasonable cause exists to believe the defendant committed the offense for which she was arrested and tried, and determine if the trial court abused its discretion in granting the petition. Applying that standard, the court held that appellant failed to carry her burden in the trial court of establishing that there was no reasonable cause to believe that she committed the offense. There was sufficient evidence for the jury to have convicted, and the court would have upheld a conviction against a claim of insufficiency of evidence. The trial court abused its discretion because its decision exceeded the bounds of reason.