State v. West

OPINION

PELANDER, Justice.

¶ 1 The issue presented is whether the same standard governs a trial court’s rulings on pre-verdict and post-verdict motions for judgment of acquittal under Arizona Rule of Criminal Procedure 20. We hold that the same standard applies, disapproving of any contrary language in State ex rel. Hyder v. Superior Court, 128 Ariz. 216, 624 P.2d 1264 (1981).

I

¶ 2 Randall and Penny West were charged with child abuse after an infant in their foster care died from severe head trauma. During their joint trial, each moved for judgment of acquittal under Rule 20(a) at the close of…