Victor v. Nebraska - 511 U.S. 1, 114 S. Ct. 1239 (1994)

Rule:

The beyond a reasonable doubt standard is a requirement of due process, but the Constitution neither prohibits trial courts from defining reasonable doubt nor requires them to do so as a matter of course. Indeed, so long as the court instructs the jury on the necessity that the defendant's guilt be proved beyond a reasonable doubt, the Constitution does not require that any particular form of words be used in advising the jury of the government's burden of proof. Rather, taken as a whole, the instructions must correctly convey the concept of reasonable doubt to the jury. 

Facts:

Two cases arose involving the validity, under the due process clause of the Federal Constitution's Fourteenth Amendment, of particular jury instructions defining "reasonable doubt" beyond which prosecutors must prove every element of a criminal offense. In one case, an individual--who had allegedly shot two men to death, killed a man who gave information on the shooting to police, and killed the man's wife--was tried in a California court on four counts of first-degree murder. In instructing the jury on the prosecution's burden of proof, the trial court defined reasonable doubt in part as (1) "not a mere possible doubt," since "everything relating to human affairs, and depending on moral evidence, is open to some possible or imaginary doubt"; and (2) that state of the case which leaves the jurors, after considering all the evidence, unable to say that "they feel an abiding conviction, to a moral certainty, of the truth of the charge." The individual was convicted, sentenced to death on one count, and sentenced to life imprisonment without possibility of parole on the other counts. The Supreme Court of California, in affirming the convictions and sentences, rejected a claim that the reasonable doubt instruction--particularly the references to "possible doubt," "moral evidence," and "moral certainty"--violated the due process clause (4 Cal 4th 155, 14 Cal Rptr 2d 342, 841 P2d 862). In the second case, a man who had allegedly killed an elderly woman by beating her and cutting her throat was tried in a Nebraska court. The court's instructions (1) defined reasonable doubt, in part, as (a) that which would cause a reasonable and prudent person, in an important transaction of life, to hesitate before taking the represented facts as true, (b) that which would not permit the jurors, after full and fair consideration of all the evidence, "to have an abiding conviction, to a moral certainty," of the accused's guilt, and (c) "an actual and substantial doubt," arising from the evidence or lack thereof rather than "from mere possibility, from bare imagination, or from fanciful conjecture"; and (2) stated that the jury could "find an accused guilty upon the strong probabilities of the case," if such probabilities were "strong enough to exclude any doubt of his guilt that is reasonable." The man was convicted of first-degree murder and sentenced to death, and this judgment was affirmed on appeal. On postconviction review, the Supreme Court of Nebraska rejected a claim that the reasonable doubt instruction--particularly the references to "moral certainty," "substantial doubt," and "strong probabilities"--violated the due process clause.

Issue:

In death penalty cases, did the state court jury instructions defining "reasonable doubt" as to proof of elements of criminal offense violate due process clause of Federal Constitution's Fourteenth Amendment?

Answer:

No.

Conclusion:

The Court affirmed. It noted that jury instructions had to be taken as a whole and that the Constitution neither prohibited nor required trial courts to define "reasonable doubt." While noting that the challenged words, by themselves, might be problematic, it did not find that the instructions, when taken as a whole, would have caused a reasonable juror to misinterpret the prosecution's burden of proof or allow them to believe they could convict the defendants on a finding of guilty based upon a degree of proof below that required by the Due Process Clause.