## Facts

- Curley was president of a business group that sought clients for government-housing and defense-related projects.
- The group distributed oral and written statements to prospective clients that materially misrepresented its financial strength, assets, cash position, federal housing approvals, and demand for its services.
- Curley and others were indicted in federal district court for mail fraud and conspiracy to commit mail fraud.
- Curley’s defense was lack of knowledge, characterizing himself as a figurehead unaware of co-defendants’ misrepresentations.
- The prosecution introduced evidence that Curley interacted directly with clients and had firsthand knowledge of the group’s financial condition.
- At the close of the government’s case, Curley moved for a directed verdict (treated as a motion for judgment of acquittal); the court denied the motion.
- Curley presented no evidence, rested, and the jury convicted him on the conspiracy count.

## Issues

1. What standard governs a trial judge’s ruling on a motion for directed verdict/judgment of acquittal in a criminal case based on insufficiency of the evidence.
2. Whether, under that standard, the evidence was sufficient to permit a reasonable jury to find Curley guilty of conspiracy beyond a reasonable doubt.

## Decision

- The court affirmed the conviction.
- A trial judge must deny a motion for judgment of acquittal if, viewing the evidence in the light most favorable to the government, reasonable jurors could differ on whether guilt was proved beyond a reasonable doubt.
- The judge may grant the motion only if a reasonable mind would necessarily have a reasonable doubt as to guilt.
- Applying that standard, the evidence permitted an inference that Curley knew of the false representations and knowingly participated in the scheme; the case was properly submitted to the jury.

## Legal Principles

- On a motion for judgment of acquittal, the judge does not weigh evidence or assess witness credibility; those tasks belong to the jury.
- The judge’s role is limited to determining whether the evidence, if believed and with reasonable inferences drawn for the government, can support guilt beyond a reasonable doubt.
- If reasonable jurors may fairly reach different conclusions from the evidence, the case must go to the jury even if an alternative innocent inference is also plausible.
- On appellate review of sufficiency, a conviction stands if a rational trier of fact could find guilt beyond a reasonable doubt; an appellate court does not re-resolve evidentiary conflicts or competing reasonable inferences.

## Conclusion

The court upheld Curley’s conspiracy conviction and articulated the governing sufficiency standard for denying a directed verdict/judgment of acquittal: the motion must be granted only when the evidence, viewed favorably to the government, could not permit any reasonable jury to find guilt beyond a reasonable doubt.


Curley v. United States, 160 F.2d 229 (D.C. Cir. 1947)