Brief of National Association of Criminal Defense Lawyers as Amicus Curiae (on petition for a writ of certiorari).
Argument: The jury system is an imperfect protection against wrongful convictions. The “Equipoise Rule” helps courts to fulfill their duty to protect defendants’ right to be convicted by proof beyond a reasonable doubt. A court must enter a judgment of acquittal if no rational factfinder could find guilt beyond a reasonable doubt. In cases where the evidence is in Equipoise, no rational factfinder could find guilt beyond a reasonable doubt. The Equipoise rule meaningfully protects defendants’ constitutional rights.