US-CA3 · jury_instructions
3d Cir. Model Jury Instr. (Criminal) 3.06
Presumption of Innocence; Burden of Proof; Reasonable Doubt
The defendant (name) pleaded not guilty to the offense(s) charged. (Name)
is presumed to be innocent. (He) (She) started the trial with a clean slate, with no
evidence against (him) (her). The presumption of innocence stays with (name) unless
and until the government has presented evidence that overcomes that presumption
by convincing you that (name) is guilty of the offense(s) charged beyond a
reasonable doubt. The presumption of innocence requires that you find (name) not
guilty, unless you are satisfied that the government has proved guilt beyond a
reasonable doubt.
The presumption of innocence means that (name) has no burden or
obligation to present any evidence at all or to prove that (he) (she) is not guilty. The
burden or obligation of proof is on the government to prove that (name) is guilty and
this burden stays with the government throughout the trial.
In order for you to find (name) guilty of the offense(s) charged, the
government must convince you that (name) is guilty beyond a reasonable doubt.
That means that the government must prove each and every element of the
offense(s) charged beyond a reasonable doubt. A defendant may not be convicted
based on suspicion or conjecture, but only on evidence proving guilt beyond a
reasonable doubt.
Proof beyond a reasonable doubt does not mean proof beyond all possible
doubt or to a mathematical certainty. Possible doubts or doubts based on
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conjecture, speculation, or hunch are not reasonable doubts. 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. It may arise from the evidence, or from the lack
of evidence, or from the nature of the evidence.
If, having now heard all the evidence, you are convinced that the
government proved each and every element of the offense charged beyond a
reasonable doubt, you should return a verdict of guilty for that offense. However, if
you have a reasonable doubt about one or more of the elements of the offense
charged, then you must return a verdict of not guilty of that offense.
Provenance
- Source
- ca3.uscourts.gov
- Retrieved
- 2026-08-19
- Edition
- 2026-08-19
- Content hash
6851f85fadeabea3d29d9d2afb75a024b0370b768b48498a8d1560baae2c4b55
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