Due Process Clause.”) Accordingly, the district court properly denied Davis’ motion to suppress. Davis next asserts that there was insufficient evidence to convict him of carjacking because (1) there was no evidence that the victim’s car was taken from his person or presence and (2) there was no evidence of intent to cause death or serious harm. A defendant challenging the sufficiency of the evidence faces a heavy burden. See United States v. Beidler, 110 F.3d 1064, 1067 (4th Cir.1997). “[A]n appellate court’s reversal of a conviction on grounds of insufficiency of evidence should be ‘confined to cases where the prosecution’s failure is clear.’ ” United States v. Jones, 735 F.2d 785, 791 (4th Cir.1984) (quoting Burks v. United States, 437 U.S. 1, 17, 98 S.Ct. 2141, 57 L. 1th Cir.1999) (<HOLDING>). These cases also make clear that the presence
holding that an arrest to retrieve car keys where ownership of the car was in dispute was not supported by probable cause holding that the presence requirement of the carjacking statute was satisfied when keys were taken from a bank employee whose car was parked in a parking lot outside the bank holding that the presence requirement of the carjacking statute was satisfied when keys were taken from a restaurant employee whose car was parked outside the restaurant holding that the factfinder may conclude that recovery is not likely when the car is left on street with keys in the car holding that restaurant that bought and sold products produced outside of state satisfied interstate commerce requirement for federal arson statute