Whether Virginia's standard of review for appellate claims of insufficient evidence in criminal convictions violates the Due Process Clause as interpreted by this Court in Jackson v. Virginia

QUESTION PRESENTED In Jackson v. Virginia, 443 U.S. 307 (1979), this Court held that the Due Process Clause requires the following standard of review for appellate claims of insufficient evidence of a criminal conviction: whether “any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” Jackson explicitly rejected a standard that asked instead whether “no evidence” supported a conviction. Setting itself apart from every other state and federal jurisdiction in the nation, Virginia has continued to apply its pre-Jackson standard of review without selfreflection: whether a criminal conviction is “without evidence to support it.” Does this standard, applied in Mr. Rams’s case, violate the Due Process Clause as interpreted by this Court in Jackson? i