Skip to main content
DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Commonwealth v. Engstrom, 122 N.E.3d 1098 (2019)

Citation
Commonwealth v. Engstrom, 122 N.E.3d 1098 (2019)
Parent Document
Commonwealth v. Engstrom, 122 N.E.3d 1098 (2019)
Jurisdiction
Massachusetts (state)
Effective Date
2019-01-03

Full Text

1,111 chars
Discussion. 1. Sufficiency of the evidence. The defendant contends that the judge erred in denying her motions for a required finding of not guilty because there was insufficient evidence to support her conviction. When reviewing a denial of a motion for a required finding of not guilty, we assess the evidence in the light most favorable to the Commonwealth to determine whether "any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt." See Commonwealth v. Latimore, 378 Mass. 671, 677 (1979), quoting Jackson v. Virginia, 443 U.S. 307, 319 (1979). To convict a defendant of negligent operation of a motor vehicle under G. L. c. 90, § 24 (2) (a ), "the Commonwealth must prove that the defendant (1) operated a motor vehicle (2) upon a public way (3) negligently so that the lives or safety of the public might be endangered." Commonwealth v. Ross, 92 Mass. App. Ct. 377, 379 (2017). Here, the defendant challenges only the third element, contending that the Commonwealth failed to prove that she operated a motor vehicle in a negligent manner.3 We disagree.