Anyone thought, or tried, to apply this limitiation in state sufficiency cases?

"[W]here a defendant moves for a judgment of acquittal at the end of the Government’s case but, after presenting evidence, fails to renew that motion, the defendant has forfeited his insufficiency challenge and our review is for a 'manifest miscarriage of justice.'” United States v. Salazar, 542 F.3d 139, 142 (5th Cir. 2008).

Read the Fifth Circuit's latest opinion at: http://www.ca5.uscourts.gov/op...11-40265-CR0.wpd.pdf

Interesting. Does that mean that a defendant who doesn't raise a motion for directed verdict at all is able to raise a sufficiency claim?