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Curley v. United States

    Brief Fact Summary.

    At trial, Curley moved for a directed verdict, which the court denied, and Curley appealed arguing that the court erred in not granting his motion for a directed verdict.

    Synopsis of Rule of Law.

    A trial court judge is required to grant a defendant’s motion for a directed verdict if, when looking at the evidence presented, no reasonable jury could find the defendant guilty beyond a reasonable doubt.

    Facts.

    Curley was a member of a company involved in government housing and defense related contracts. During preliminary negotiations with certain prospective clients, the company seriously misrepresented various details about their financial status and purported that the group held significant assets and cash, already had obtained approval for housing projects from the Federal Housing Administration, and the fact they were sought out for other business contracts. All of these misrepresentations were contained in brochures, contracts, and communications with clients. Curley and his co-defendants were indicted on multiple charges including: conspiracy to commit mail fraud and violation of the Federal mail fraud statute. Curley claimed he had no knowledge of the wrongdoing of his co-conspirators. However, Curley also had direct knowledge of the company finacial status and had  personally interacted with clients. Curley moved for a directed verdict, which the court denied.

    Issue.

    Whether a trial judge is required to grant a motion for a directed verdict when no reasonable jury could find the defendant guilty beyond a reasonable doubt based on the evidence presented by the prosecution?

    Held.

    Yes, whenever the evidence is such that no reasonable jury could find the defendant guilty beyond a reasonable doubt after evaluation of all the evidence, then the judge must grant a motion for a directed verdict.

    Discussion.

    The role of the jury includes things such as weighing the evidence, assessing the credibility of witnesses, and drawing reasonable inferences based on their assessments. The judge must determine based on the evidence presented whether such evidence permits a jury to find whether or not a defendant can be found guilty beyond a reasonable doubt. If the jury, when weighing the evidence, cannot possibly find the defendant guilty beyond a reasonable doubt, the judge must grant the acquittal. If the judge determines that a reasonable jury could find the defendant guilty beyond a reasonable doubt or it is possible for a jury to do so, they he must send the case to the jury for them to decide. Here, on the one hand, a reasonable jury could find that Curley knew of the inner workings of the wrongdoing and had direct knowledge of such. A jury could also find that Curley was a mere figurehead of the company who had no idea about the wrongdoing by his co-conspirators. Thus, the judge was not required to grant the motion for a directed verdict.


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