Whether Virginia's standard of review for appellate claims of insufficient evidence of a criminal conviction 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.” The Jackson Court explicitly rejected a standard that asked 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 own standard of review: a pre-Jackson relic that asks only whether a criminal conviction is “without evidence to support it.” Does this standard, applied in Mr. Johnson's case, violate the Due Process Clause as interpreted by this Court in Jackson? i