David Curran v. United States

Review of sufficiency of the evidence is a critical function of appellate courts. It ensures that any conviction was supported at trial by proof beyond a reasonable doubt. The standard is a fundamental principle of American law and the bedrock of due process, and appellate review ensures it is met in every criminal case where a conviction is returned. In its 2013 decision United States v. Caraballo-Rodriguez, 726 F.3d 418 (3d Cir. 2013), the Third Circuit announced a new standard as to one element of sufficiency review, shared unity of purpose, for drug conspiracy cases. This change has brought it into conflict with other circuit courts. The question presented is as follows: Whether the Third Circuit’s standard of review of sufficiency of evidence in drug conspiracy cases is in conflict with other circuits and falls below that required for due process.