United States v. Akil Daniels

MEMORANDUM

A jury found Akil Daniels guilty of three counts of bank robbery and one count of attempted bank robbery. Daniels appeals his convictions and his sentence. We have jurisdiction under 28 U.S.C. § 1291 and 18 U.S.C. § 3742 (a). We affirm.

Daniels contends that the evidence was insufficient to support his convictions. This court must decide “whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” Jackson v. Virginia, 443 U.S. 307, 319 , 99 S.Ct. 2781 , 61 L.Ed.2d 560 (1979).

We begin with Daniels’s bank robbery convictions, Counts 1, 2, and 4 of the indictment. Daniels confessed to the robberies. For a confession to serve as the basis for a conviction, the government need only provide evidence sufficient to corroborate the confession. United States v. Valdez-Novoa, 760 F.3d 1013, 1032 (9th Cir.2014). As to Count 1, the confession was corroborated by surveillance photos of the robbery and an in-court identification by an eyewitness. As to Count 2, the confession was corroborated by surveillance photos and a photo-lineup identification by…