In any criminal case—including a federal criminal case—the prosecutors bear the burden of proof to demonstrate that the defendant has committed the crime in question. But, what does it mean to prove the defendant’s guilt? The standard of proof in a criminal case is “beyond a reasonable doubt,” which means that the jury or the judge must believe “beyond a reasonable doubt” that the suspect did what prosecutors say he or she did. The tricky part of this standard, however, is defining reasonable doubt.

Defining Reasonable Doubt

Depending on the case in question, prosecutors may attempt to explain to jurors what reasonable doubt means. Defense attorneys sometimes present a definition of their own, as well. For example, a prosecuting attorney in California once compared the standard to a puzzle that is missing a single piece, suggesting that even with a missing piece, it was still clear what the puzzle showed. The case resulted in a conviction that was later overturned on appeal because by attempting to define reasonable doubt, the prosecutor effectively told jurors they could convict the defendant based on incomplete information.

For reasons like this, the parties in a criminal case are generally not encouraged to offer their own definitions of reasonable doubt. The same is true if the judge is not careful about explaining reasonable doubt to the jurors.

Federal Jury Instructions on Reasonable Doubt

At the federal level, there are a couple of different ways in which judges may instruct juries on what reasonable doubt should mean, as approved by the U.S. Supreme Court. One such instruction tells jurors that they must be “firmly convinced of the defendant’s guilt,” and if they “think there is a real possibility that he is not guilty, [the jury] must give him the benefit of the doubt and find him not guilty.

Another version of model jury instructions exists as well. Using this version, a judge may tell a jury prior to deliberations, “A reasonable doubt is a fair doubt based on reason, logic, common sense, or experience. It is a doubt that an ordinary reasonable person has after carefully weighing all of the evidence, and is a doubt of the sort that would cause him or her to hesitate to act in matters of importance in his or her own life.”

Appealing Based on Jury Instructions

When a party in a case tries to define reasonable doubt or the judge gives erroneous instructions to the jury, it is up to the defense lawyer to act quickly so that the issue can be preserved for appeal. To do so, the defense attorney must object and have the objection noted in the record. This allows an appeals court to review the instructions that were given without considering how the lower court ruled. Failing to object immediately could make appealing an improper instruction difficult and, in some cases, practically impossible.

Contact a Chicago Federal Criminal Defense Lawyer

If you are facing federal or state criminal charges in Illinois, it is important to work with a strong, tenacious advocate who is prepared to uphold the reasonable doubt standard. Contact the Law Offices of Hal M. Garfinkel to discuss your situation with an experienced Chicago federal criminal defense attorney today. Call 312-270-0999 for a free consultation.



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