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Name: People v. Dickens
Case #: E036144
Court: CA Court of Appeal
District 4 DCA
Division: 2
Opinion Date: 07/05/2005

In this People’s appeal following a prosecution for attempted murder, the reviewing court found no abuse of discretion in granting a defendant’s motion for new trial on the ground that there was insufficient evidence of intent to kill. The People’s complaint on appeal was that the trial court had failed to articulate its reasons for finding the evidence insufficient, and because the jury verdict was supported by substantial evidence, this failure to articulate reasons evinced an abuse of discretion. The Court of Appeal rejected the argument, declining to follow the holding in People v. Taylor (1993) 19 Cal.App.4th 836. The court held that the trial court’s function in reviewing a motion for new trial is to independently determine whether it is satisfied that there is sufficient credible evidence to sustain the verdict. A reviewing court’s role, moreover, is to determine whether the trial court’s ruling is supported by substantial evidence. Here, the Court of Appeal could not say as a matter of law that no substantial evidence supported the trial judge’s finding, and thus no abuse of discretion was apparent.