CALCRIM No. 220

The fact that a criminal charge has been filed against the defendant[s] is

not evidence that the charge is true. Y ou must not be biased against the

defendant[s] just because (he/she/they) (has/have) been arrested, charged

with a crime, or brought to trial.

A defendant in a criminal case is presumed to be innocent. This

presumption requires that the People prove a defendant guilty beyond a

reasonable doubt. Whenever I tell you the People must prove something,

I mean they must prove it beyond a reasonable doubt [unless I

specifically tell you otherwise].

Proof beyond a reasonable doubt is proof that leaves you with an

abiding conviction that the charge is true. The evidence need not

eliminate all possible doubt because everything in life is open to some

possible or imaginary doubt.

In deciding whether the People have proved their case beyond a

reasonable doubt, you must impartially compare and consider all the

evidence that was received throughout the entire trial. Unless the

evidence proves the defendant[s] guilty beyond a reasonable doubt, (he/

she/they) (is/are) entitled to an acquittal and you must find (him/her/

them) not guilty.

New January 2006; Revised August 2006, February 2013