State of Arizona, Appellant v. Randall D. West and Penny A. West, Appellees

Summary

The Arizona Supreme Court held that the same standard governs a trial court's rulings on pre-verdict motions for judgment of acquittal under Rule 20(a) and post-verdict renewed motions under Rule 20(b): the sole question is whether the record contains substantial evidence to warrant a conviction. The court disapproved and disavowed Hyder's contrary conditions, which had confined post-verdict grants to cases where the judge considered improper evidence and changed prior evidentiary rulings, reasoning that those conditions contradict Rule 20's text, lack supporting authority, raise due process concerns, and distort incentives. Evidentiary sufficiency under Rule 20 is a question of law reviewed de novo, and the trial court may not reweigh evidence or disregard reasonable inferences. Because the court of appeals had evaluated the trial court's ruling under Hyder's now-discarded limitation, the supreme court vacated the court of appeals' opinion and remanded for a fresh sufficiency review.