3d Cir. Model Jury Instr. (Criminal) 4.13

When the identity of the person who committed a crime is in question,

the parties may introduce (fingerprint)(DNA)(handwriting) evidence to try to

prove who committed the crime. To do this, a party may present a “known”

sample of a person’s (fingerprint)(DNA)(handwriting), one that is

(proved)(admitted) to come from that person. This known

(fingerprint)(DNA)(handwriting) sample is then compared with any

(fingerprint)(DNA)(handwriting) being introduced to prove who committed the

crime. In this case (describe evidence produced; e.g., the “known” sample is the

fingerprint card and testimony produced by the government which, if believed,

establishes that the fingerprints on the card are the defendant’s and the disputed

evidence is the fingerprint that was found at the scene of the crime.)

[In this case you also heard the testimony of a witness who claims special

qualification in the field of (fingerprint identification)(DNA analysis)(handwriting

identification). The witness was allowed to express an opinion in order to help you

decide whether the disputed (fingerprint)(DNA)(handwriting) connected to the

crime in question is (the defendant)(name of suspect other than defendant)’s

(fingerprint)(DNA)(handwriting). You may therefore consider the witness’s

opinion in reaching your independent decision on this issue.]