In our review, we give due deference to the jury's findings of fact, resolution of conflicting evidence and assessment of witness credibility. Burlas v. State, 185 Md. App. 559, 568-69 (2009). This is so even in cases where "generally, proof of guilt based in whole or in part on circumstantial evidence is no different from proof of guilt based on direct eyewitness accounts."
" In the context of vehicular manslaughter, "gross negligence" means "a wanton or reckless disregard for human life." Burlas v. State, 185 Md. App. 559, 569-70 (2009) (internal quotations and citations omitted). Mr. Sanchez argues that the State provided insufficient evidence to prove vehicular manslaughter under a gross negligence theory because their experts admitted that it was impossible to establish when and by which impact the injuries and deaths occurred.
In other words, we "`give deference to all reasonable inferences [that] the fact-finder draws, regardless of whether . . . [we] would have chosen a different reasonable inference.'" Burlas v. State, 185 Md.App. 559, 568, 971 A.2d 937 (quoting Suddith, 379 Md. at 430, 842 A.2d 716), cert. denied, 410 Md. 166, 978 A.2d 245 (2009). In our independent review of the evidence, we do not distinguish between circumstantial and direct evidence because "[a] conviction may be sustained on the basis of a single strand of direct evidence or successive links of circumstantial evidence."
When reviewing the sufficiency of the evidence to support a criminal conviction, we must determine, after viewing the evidence in the light most favorable to the State, if "`any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.'" Burlas v. State, 185 Md.App. 559, 568, 971 A.2d 937 (quoting Jackson v. Virginia, 443 U.S. 307, 319, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979)), cert. denied, 410 Md. 166, 978 A.2d 245 (2009). If the evidence "`showed directly, or circumstantially, or supported a rational inference of facts which could fairly convince a trier of fact of the defendant's guilt of the offenses charged beyond a reasonable doubt[,]' then we will affirm the conviction."
Palmer v. State , 223 Md. 341, 353, 164 A.2d 467 (1960) (citation omitted). See alsoBurlas v. State , 185 Md. App. 559, 578, 971 A.2d 937 (2009) (that the victim's car did not pass inspection or might have sped up did not relieve defendant of responsibility). In Palmer , we held a mother liable for gross negligence involuntary manslaughter when she failed to prevent her husband's savage beatings of her daughter. Significantly, the Court concluded that it was not necessary that the mother's grossly negligent conduct be the sole reason for her daughter's death.
April 26, 2010. Appeal from the Superior Court, Pa.Super., 971 A.2d 937 Dispositions of Petitions for Allowance of Appeals Denied.
Denied August 24, 2009. Reported below: 185 Md.App. 559, 971 A.2d 937. Petitions for writ of certiorari Denied.
Sequeira v. State, 250 Md.App. 161, 203 (2021). The court does not distinguish between circumstantial and direct evidence. Burlas v. State, 185 Md.App. 559, 569 (2009); see also State v. Smith, 374 Md. 527, 533-34 (2004) ("[G]enerally, proof of guilt based in whole or in part on circumstantial evidence is no different from proof of guilt based on direct eyewitness accounts.")
When reviewing the sufficiency of the evidence to support a criminal conviction, we must determine, after viewing the evidence in the light most favorable to the State, if "'any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.'" Burlas v. State, 185 Md.App. 559, 568 (2009) (quoting Jackson v. Virginia, 443 U.S. 307, 319 (1979)). "If the evidence 'either showed directly, or circumstantially, or supported a rational inference of facts which could fairly convince a trier of fact of the defendant's guilt of the offenses charged beyond a reasonable doubt[,]' then we will affirm the conviction."
That the court was unpersuaded by Marchsteiner's claims regarding his mental health does not mean that the court's guilty finding was erroneous. See Burlas v. State, 185 Md.App. 559, 579 (2009) (noting that "it is nearly impossible for a verdict to be clearly erroneous or an abuse of discretion or legally in error when it is based ... only on the fact-finder's being unpersuaded") (citations and quotations omitted). Moreover, in reviewing whether the evidence was sufficient, we are not concerned with what the fact-finder could have done with the evidence.