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Directed-verdict standard

Presumed Innocent

The Directed-verdict standard is the test applied when a defendant asks the judge to end a criminal trial because the prosecution has not offered enough evidence for a reasonable jury to convict. In Rusty Sabich’s trial, the standard became more than a procedural checkpoint: it determined how the judge had to view the state’s evidence, left room for consequential judicial discretion, and ultimately provided the basis for dismissing the case before the jury deliberated.

The motion and its standard

Rusty Sabich prepares for the motion as the state’s case approaches its end. The defense must ask the judge for a judgment of acquittal, arguing that the evidence cannot support a conviction. In assessing that request, the judge must view the evidence in the light most favorable to the state. That means he cannot simply resolve disputed testimony for the defense; for purposes of the motion, he must accept the prosecution’s account, including Eugenia Martinez’s testimony, even its more questionable elements.

The usual result is that the trial continues if a reasonable jury could find the defendant guilty. The motion is therefore a steep challenge for the defense, not a general invitation for the judge to decide which side has the more persuasive case. Yet the ruling is unreviewable, and the state may not appeal it. Rusty recognizes that some judges, including Larren Lyttle, are known to use the motion as a means of imposing the result they favor. The standard thus combines a prosecution-favorable view of the evidence with a final decision entrusted to the trial judge.

The evidentiary setting

The stakes arise from a case built on circumstantial evidence. The prosecution plans to rely on fingerprints associated with a missing glass, telephone records showing a call from Rusty’s home to Carolyn Polhemus’s apartment before the murder, scientific evidence concerning semen and Carolyn’s use of a contraceptive, and fibers matching carpeting from Rusty’s home. Witnesses include Dan Lipranzer, who is expected to address Rusty’s instructions about the home telephone records, and Mrs. Krapotnik, who identified Rusty as someone she had seen in Carolyn’s building but was uncertain that he was the stranger she observed on the night of the murder. No listed witness claims to have seen Rusty kill Carolyn or heard him confess.

Before the state completes its case, the missing glass creates a separate legal dispute. After a six-hour search of the police evidence room fails to locate it, the defense argues that fingerprint testimony should not be admitted when it has had no opportunity to examine the physical exhibit. Lyttle nevertheless allows the testimony, relying on the combined account of witnesses to establish that the prints had been lifted from the glass. His ruling acknowledges both the defense’s inability to inspect the object and the evidence room’s longstanding record of careless handling. He says that he is reluctant to admit the proof, notes that bad faith could end the prosecution, but assumes it has not occurred and plans a strongly worded limiting instruction. The episode shows how evidentiary rulings shape the material that will later be assessed under the directed-verdict standard.

Preparing and applying the motion

As the prosecution’s proof gathers momentum, Alejandro Stern assigns Rusty to research cases condemning the absence of motive in circumstantial cases. The defense also considers how to challenge Dr. Kumagai, whose scientific evidence is central to the state’s presentation. The standard does not allow the judge simply to weigh the defense’s alternative explanation against the prosecution’s case; the immediate question is whether the prosecution’s evidence, taken in its favor, can legally support a conviction.

After reflecting on the case, Lyttle concludes that it cannot. He distinguishes grounds for suspicion from proof sufficient to put Rusty before a jury. In his view, the case lacks proof of motive, concrete evidence of an intimate relationship, and effective proof that Rusty had sexual relations with Carolyn on the night she died. He also finds no direct evidence that Rusty murdered her. The missing glass matters to his assessment: he says that finding it might have made him more confident in the state’s case, but the exhibit remains unavailable. Although he had earlier recognized reasonable grounds for suspicion, he now considers the evidence inadequate to let the jury deliberate.

Dismissal and limits of the ruling

Lyttle’s decision ends the trial without a jury verdict. Nico Delia Guardia disagrees with the judge’s conclusion but accepts that it falls within the law and moves to dismiss the case. Lyttle discharges Rusty and calls what has happened a disgrace to the cause of justice. The prosecution does not appeal, consistent with the rule that makes this kind of ruling unreviewable.

The ruling determines the legal sufficiency of the state’s case, not the underlying facts of Carolyn’s murder. Stern later argues that Lyttle’s handling was evenhanded: had the judge wanted a convenient way to terminate the proceedings, he could have excluded the fingerprint testimony when the glass could not be found. Three jurors tell reporters they would not have voted to convict, but Rusty and Stern recognize that their statements cannot establish what the remaining jurors would have decided. The standard closes the courtroom process while leaving the distinction between suspicion, legal proof, and factual truth unresolved.