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Friday, April 29, 2011
Judge’s Duty To Consider Non-Standard/Pattern Instructions (Florida)
“Using ‘standard jury instructions does not relieve the trial court of its obligation to determine whether the standard instructions accurately and adequately state the law.’ Id. If the trial court determines that the instruction is ‘erroneous or inadequate,’ the court may then modify the standard jury instruction as the "trial judge shall determine to be necessary to instruct the jury accurately and sufficiently. [Citation.]" Peters v. State, 33 So. 3d 812, 814 (Fla. Dist. Ct. App. 4th Dist., No. 4D08‑3299, 4/28/2010).
Thursday, April 28, 2011
Failure To Request Or Object To An Instruction Is Excused If Request Or Objection Would Have Been Futile (California)
“A defendant will be excused from the necessity of either a timely objection and/or a request for admonition if either would be futile.” People v. Redd, 48 Cal.4th 691, 745 (Cal., No. S059531, 4/29/2010). This principle may make an instructional issue cognizable where the judge has foreclosed objection or indicated that an instructional request will be denied. For example, if the judge states that only established pattern instructions will be given this could excuse the failure to request a non-pattern instruction.
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Wednesday, April 27, 2011
New Trial Required Where Jurors Violated Judge’s Express Admonition Not To Consult The Internet For Information
In State v. Aguilar, 224 Ariz. 299 (Ariz. Ct. App. 2D10) the judge admonished the jurors at the beginning of trial to "not consult any source, such as . . . the [I]nternet for information," and then reminded the jury to observe the admonition throughout the trial. However, two jurors conducted Internet research on the legal definitions of terms in the court's final instructions, communicated their research to other jurors, and three additional jurors considered the research before joining the other jurors in unanimously convicting the defendant of attempted first degree murder.
The superior court found the State had "defeated the presumption of prejudice by proving beyond a reasonable doubt that the [Internet definitions] considered by the jury . . . did not taint the jury's verdicts," and denied Appellants' motions.
The reviewing court ordered a new trial after considering the following factors which should be considered: (1) The importance of the words; (2) The extent to which the legal and dictionary definitions differ; and (3) The extent to which the jury discussed and emphasized the extrajudicial definitions. Id. at 302-306.
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Tuesday, April 26, 2011
Use Of The Word “May” Makes A Presumption Permissive Rather Than Mandatory
Mercado v. Crawford, (D. Nev., No. 3:02‑cv‑0357‑ECR‑RAM, Apr. 23, 2010) concluded that a malice instruction is not unconstitutional if it gives a permissive, not mandatory, directive. “The word ‘may,’ as defined by Merriam‑Webster's Collegiate Dictionary, is one used to indicate the possibility or probability of a thing happening, indicating permission to do some thing. Id., 10th Ed., p. 717. Thus, its use cannot and does not create a mandatory presumption in this jury instruction.” Ibid., see also Leonard v. State, 117 Nev. 53, 78‑79, 17 P.3d 397, 413 (2001); Cordova v. State, 116 Nev. 664, 6 P.3d 481, 482‑83 (2000) [use of word "may" eliminates the issue of a mandatory presumption].
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Monday, April 25, 2011
Sample Instruction: Potential Offer And Compromise With IRS Is Not Evidence Of Wrongdoing
You have heard testimony in this case about discussions surrounding a potential offer and compromise with the IRS. Evidence of offer and compromise is not itself evidence of wrongdoing or admission of guilt to the underlying charges. You may consider all other evidence you may have heard regarding what the defendants did or did not do in reaching your decision.
Source: Given in United States v. Ross, (D. Haw., No. 08‑00223 DAE, 4/26/2010).
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Friday, April 22, 2011
Strategy Note: Informing Jury That Defense Counsel Made The Decision Not To Call The Defendant To Testify
In United States v. Kale, 2010 U.S. Dist. LEXIS 41662, 32‑35 (E.D. Pa., No. 09‑264‑3, Apr. 26, 2010) defense counsel made the following statement during closing argument:
Let me deal right here and now with one thing. I cut this trial short by not calling Trance Kale to the stand. The Court will instruct that when you go into that jury room, you cannot [consider] the fact that Trance Kale did not testify in any way in arriving at your verdict. If you mention it in the jury room, if you even think about it, you will be depriving him of a fair trial, and depriving him of the Constitutional Rights afforded to all of us. If you hold it against him, you will also be violating your oath. And I know there's not one of you here that wants to do that.
This statement opened the door for the prosecutor to request a “curative” instruction. Thus, it was not error for the judge to instruct, over defense objection, as follows:
You'll recall that during the course of this case I did charge you or instruct you . . . that there's a presumption of innocence with respect to a defendant, and that means that a defendant has no burden or obligation to present any evidence at all, nor does the defendant have any burden or obligation to take the witness stand. It's his constitutional privilege not to testify or even call any evidence if he so chooses in that regard. . . .
I recall that Defense counsel told you that he didn't call the defendant to the stand in this case, and that he cut the trial short in that regard.
. . .
[T]hat comment has absolutely nothing to do with respect to a defendant's constitutional right not to testify, and you should disregard that comment in all respects. It's a comment that has nothing to do with any decision that you should take into consideration in connection with what happened in this case.
The defendant had a right, a constitutional right not to take the witness stand, and that was his decision to make, and so be it. Don't connect that in any way, shape, or form with . . . defendant counsel's statement that he . . . made that decision not to call the defendant to the stand, and that he cut the trial short in that regard.
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Thursday, April 21, 2011
Sample Instruction: Response To Prosecutor’s Argument That The “Job” Of The Defense Is To Lead The Jury “Astray”
Ladies and gentlemen, the job of the defense is to provide a defense. How they do that within the bounds is perfectly acceptable. . . . And has been perfectly acceptable.
Source: Smith v. Sherry, (E.D. Mich., No. 07‑15231, Apr. 26, 2010) [instruction cured prejudice from prosecutor’s argument that “The defense has one job, ladies and gentlemen and that job is to lead you astray on any issue it can. Any side issue. To take you away from the physical evidence that I've been talking to you about . . . .].
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Wednesday, April 20, 2011
Identity Theft: Refusal To Instruct On Knowledge Element Was Reversible Error (2nd Circuit)
In United States v. Tureseo, 566 F.3d 77, 82‑83 (2d Cir. 2009), the defendant had been convicted in a jury trial of aggravated identity theft under 18 USC 1028A(a)(1) because he had used another person's birth certificate to make a false claim of U.S. citizenship. The Second Circuit vacated this conviction because the trial court had refused to instruct the jury "that an aggravated identity theft conviction requires a finding that [the defendant] knew that the means of identity he used . . . belonged to another person, i.e., an actual person." Id. at 86; see United States v. Flores‑Figueroa, 129 S. Ct. 1886, 173 L. Ed. 2d 853 (2009). The court concluded that the error was not harmless because it was questionable whether the defendant, who had never met and could not identify the person to whom the birth certificate belonged, knew that the birth certificate was real.
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Tuesday, April 19, 2011
Statutory Interpretation: Adverb Such As Knowingly Applies To All Subsequently Listed Elements (USSC)
In United States v. Flores‑Figueroa, 129 S. Ct. 1886, 173 L. Ed. 2d 853 (2009) the defendant had worked under a false name, using a social security number and alien registration number that did not belong to a real person. Flores‑Figueroa, 129 S.Ct. at 1889. After six years of using such counterfeit identity information, he presented his employer with a new counterfeit alien registration card and social security card, which used his real name but with alien registration and social security numbers that were assigned to actual people. Id. After the government charged him with, among other things, aggravated identity theft under 18 USC 1028A(a)(1), he moved for acquittal, claiming that the government "could not prove that he knew that the numbers on the counterfeit documents were numbers assigned to other people." Id. (emphasis in original). The government replied ‑‑ and the district court agreed ‑‑ that the government need not prove such knowledge. Id. After a bench trial, the district court found the defendant guilty of aggravated identity theft, a determination upheld by the court of appeals. Id. The Supreme Court granted certiorari to consider the "knowledge" issue. Id.
In their arguments before the Court, the parties agreed that the provision of 18 USC 1028A(a)(1) that requires the government to prove that a defendant "knowingly transfer[red], possesse[d], or use[d], without lawful authority, a means of identification of another person" applies "only where the offender knows that he is transferring, possessing, or using something." Id. (emphasis in original). The parties did not agree, however, "whether the provision requires that a defendant also know that the something he has unlawfully transferred is, for example, a real ID belonging to another person rather than, say, a fake ID . . . ." Id. (emphasis in original).
The United States Supreme Court held that § 1028A(a)(1) required that the defendant knew that he was unlawfully transferring, possessing, or using real means of identification. Id. at 1894. The Court explained that "[a]s a matter of ordinary English grammar, it seems natural to read the statute's word 'knowingly' as applying to all the subsequently listed elements of the crime." Id. at 1890. "In ordinary English, where a transitive verb has an object, listeners in most contexts assume that an adverb (such as knowingly) that modifies the transitive verb tells the listener how the subject performed the entire action, including the object as set forth in the sentence." Id. Furthermore, "fully consistent with this ordinary English usage . . . . courts ordinarily read a phrase in a criminal statute that introduces the elements of a crime with the word 'knowingly' as applying that word to each element." Id. at 1891 (citations omitted). Accordingly, the Court held that, pursuant to "the ordinary meaning, in English or through ordinary interpretive practice," the word "knowingly" in § 1028A(a)(1) modifies not only the phrase "transfers, possesses, or uses" but also the phrase "of another person." Id. at 1894. The Court concluded therefore that " § 1028A(a)(1) requires the Government to show that the defendant knew that the means of identification at issue belonged to another person." Id.
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Monday, April 18, 2011
Sample Limiting Instruction: Hearsay Admitted For Nonhearsay Purpose – Communication Of IRS Opinion To Defendant
I have now received into evidence these exhibits that the witness is receiving . . . which contain the conclusion that remuneration which ________ <name of defendant> received from ________ <employer> constituted wages to ________ <name of defendant>.
This evidence has been admitted only for the purpose of establishing that the Internal Revenue Service was of the view that ________’s <employer> payments to ________ <name of defendant> constituted wages and that this view was communicated to ________ <employer>.
Source: Given and approved in United States v. Hendrickson, (E.D. Mich., No. 08 20585, 4/26/2010).
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4.3.2 - Cautionary And Limiting Instructions: Requests And Objections
Chapter 26: Limited Purpose Evidence
272.5.5 - Circumstances Where Cautionary And Limiting Instructions May Be Effective
297.3.2 - Cautionary Or Limiting Instructions May Emphasize The Prejudicial Matter
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Evidence: Limiting Instructions
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PG X(E)(19)(2) Cautionary/Limiting Instructions May Emphasize The Prejudicial Matter
PG X(E)(19)(3) Defendant Should Decide Whether Cautionary/Limiting Instruction Is Given
This evidence has been admitted only for the purpose of establishing that the Internal Revenue Service was of the view that ________’s
Source: Given and approved in United States v. Hendrickson, (E.D. Mich., No. 08 20585, 4/26/2010).
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4.3.2 - Cautionary And Limiting Instructions: Requests And Objections
Chapter 26: Limited Purpose Evidence
272.5.5 - Circumstances Where Cautionary And Limiting Instructions May Be Effective
297.3.2 - Cautionary Or Limiting Instructions May Emphasize The Prejudicial Matter
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Evidence: Limiting Instructions
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PG X(E)(19)(2) Cautionary/Limiting Instructions May Emphasize The Prejudicial Matter
PG X(E)(19)(3) Defendant Should Decide Whether Cautionary/Limiting Instruction Is Given
Thursday, April 14, 2011
Preservation Of Instructional Issues: Factual Basis And Legal Theory Must Be Specified (Texas)
In Mays v. State, 318 S.W.3d 368 (Tex. Crim. App., No. AP‑75,924, 4/28/2010) the defendant forfeited any error on appeal because he failed to specify what facts or legal theory would support submission of any of his defense theory instructions. “Merely submitting a multi‑page list of bare‑bones objections to the failure to include various statutory defenses and affirmative defenses does not sufficiently direct the trial judge's attention to the specific facts or theory supporting submission of such a charge. As this Court noted almost one‑hundred years ago, a defendant who files a laundry‑list of written objections to the charge must also specify the legal or factual reasons why he believes himself entitled to such special instructions. Unexplained lists of objections and requests for instructions risk being considered "sandbagging" objections that fail to preserve any issue for review.” Mays v. State, 318 S.W.3d 368, 384-85 (Tex. Crim. App., No. AP‑75,924, 4/28/2010) [footnotes omitted].
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PG VII(B)(2) - Federal Claim Must Be Specified
Wednesday, April 13, 2011
Mistake Of Fact May Not Be Based On Mental Illness (Texas)
In Mays v. State, 318 S.W.3d 368 (Tex. Crim. App., No. AP‑75,924, 4/28/2010) the reviewing court explained that mental illness may not be considered vis‑à‑vis mistake of fact. In Texas the “statutory mistake‑of‑fact defense explicitly requires that the defendant's mistaken belief about the existence of a fact is a ‘reasonable’ one ‘that would be held by an ordinary and prudent man in the same circumstances as the actor.’ See Tex. Penal Code § 1.07(a)(42); Winkley v. State, 123 S.W.3d 707, 712 (Tex. App.– Austin 2003, no pet.). Although the ‘reasonableness’ of a mistaken belief is generally a question for the jury, appellant cannot rely upon evidence of his paranoia and psychotic thinking to raise a ‘reasonable’ mistaken belief concerning the officers' intentions. The law examines ‘reasonableness’ from the perspective of an ordinary and prudent person, not from that of a paranoid psychotic who is, by psychiatric definition, ‘unreasonable’ in his imagined suspicions, delusions, and fears. Mental disease is not an attribute of the reasonable, ordinary and prudent person. Thus, although the general rule is that the jury must determine the relative credibility of the evidence raising a ‘reasonable belief’ about a fact, reliance upon paranoid beliefs and delusions negates the type of reasonableness that an ordinary and prudent person would have under the circumstances.” Mays v. State, 318 S.W.3d 368, 383 (Tex. Crim. App., No. AP‑75,924, 4/28/2010) [footnotes omitted.].
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Jury Must Consider Defendant’s Mental Condition At The Time Of The Offense And Not Current Condition
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Tuesday, April 12, 2011
Judge Did Not Abuse Discretion In Declining To Poll Jurors About Inflammatory Newspaper Editorial (Texas)
In Mays v. State, 318 S.W.3d 368, 378 (Tex. Crim. App., No. AP‑75,924, 4/28/2010) the trial judge did not abuse his discretion by declining to poll the jury rather than risk exposing the jury to the existence of the Athens Daily Review editorial for the first time.
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F 101.8 Inst 2 (a‑g) - Duty To Report: Juror Who Becomes Aware During Trial Of Matter Affecting Ability To Be Fair And Impartial
Monday, April 11, 2011
Judge Should Not Declare A Witness To Be An Expert In Front Of The Jurors (6th Circuit)
In United States v. Johnson, 488 F.3d 690, 697 (6th Cir. 2007) the 6th Circuit observed that "[w]hen a court certifies that a witness is an expert, it lends a note of approval to the witness that inordinately enhances the witness's stature and detracts from the court's neutrality and detachment." Thus, the proper procedure for qualifying expert witnesses in federal court should be as follows: "Except in ruling on an objection, the court should not, in the presence of the jury, declare that a witness is qualified as an expert or to render an expert opinion, and counsel should not ask the court to do so." ABA Civil Trial Practice Standard 17 (Feb. 1998); see also Jones, Rosen, Wegner & Jones, Rutter Group Practice Guide: Federal Civil Trials & Evidence § 8:1548.1 (The Rutter Group 2006). The proponent of the witness should pose qualifying and foundational questions and proceed to elicit opinion testimony. If the opponent objects, the court should rule on the objection, allowing the objector to pose voir dire questions to the witness's qualifications if necessary and requested. See Berry v. McDermid Transp., Inc., 2005 U.S. Dist. LEXIS 19568, 2005 WL 2147946, at *4 (S.D.Ind. Aug.1, 2005) (stating that "counsel for both parties should know before trial that the court does not 'certify' or declare witnesses to be 'experts' when 'tendered' as such at trial. Instead, if there is an objection to an offered opinion, the court will consider the objection. The court's jury instructions will refer to 'opinion witnesses' rather than 'expert witnesses'"); see also Jordan v. Bishop, 2003 U.S. Dist. LEXIS 4586, 2003 WL 1562747, at *2 (S.D. Ind. Feb.14, 2003). The court should then rule on the objection, "to the extent practicable, so as to prevent inadmissible evidence from being suggested to the jury by any means." [Fed. R. Evid. 103(c).] Johnson, at 697‑98; but see State v. Barlow, (Tenn. Crim. App., No. W2008‑01128‑CCA‑R3‑CD, Apr. 26, 2010) [no obligation to follow the procedure established by the Sixth Circuit for qualifying witnesses].
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Friday, April 8, 2011
Identity Theft: Victim Must Be Real Person
In Commonwealth v. Newton, 2010 PA Super 75, P26‑P28 (Pa. Super. Ct., No. 1298 MDA 2009, 4/30/2010) Newton was first charged only with identity theft with respect to one Bruton Cole. However, the prosecution presented no evidence whatsoever indicating that Bruton Cole was a living human being. Rather, it appeared from the record that Bruton Cole was merely a fictitious name, with no real identifying information, which Newton used to obtain computers to ship overseas. Thus, because the prosecution had the burden to prove every element of the crime beyond a reasonable doubt, and failed to do so, the court vacated the conviction and judgment of sentence for identity theft.
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Thursday, April 7, 2011
Sample Instruction: Accomplice Testimony Subject To Grave Suspicion (Ohio)
The testimony of an accomplice does not become inadmissable because of his or her complicity, moral turpitude, or self‑interest, but the admitted or claimed complicity of a witness may affect his or her credibility and make that testimony subject to grave suspicions, and require that it be weighed with great caution.
It is for you, the jurors, in light of all the facts presented to you from the witness stand, to evaluate such testimony and to determine its quality and worth or its lack of quality and worth.
Source: Given and approved in State v. Kent, 2010 Ohio 1851, P13‑P14 (Ohio Ct. App., Cuyahoga County, No. 90795, Apr. 27, 2010).
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Wednesday, April 6, 2011
Burden Of Proof: “All” Elements Versus “Each And Every” Element (Ohio)
In State v. Kent, 2010 Ohio 1851, P18‑P21 (Ohio Ct. App., Cuyahoga County, No. 90795, Apr. 27, 2010) the trial court instructed the jury, with regard to the offense of aggravated murder, as follows:
"Ladies and gentlemen, if you find that the State failed to prove beyond a reasonable doubt all the essential elements of aggravated murder, then your verdict must be not guilty of that offense. In that event, or if you are unable to agree unanimously, you will continue your deliberations . . ."
Kent argued on appeal that the trial court's use of the word "all," instead of "each and every," with regard to proof beyond a reasonable doubt and the elements associated with the offense of aggravated murder, constituted an erroneous jury instruction.
The reviewing court concluded that use of the term "all," instead of "each and every," when instructing the jury with regard to the elements that must be proved beyond a reasonable doubt, did not circumvent the legal principles and law pertinent to the charged offense of aggravated robbery.
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F 220 Note 12 - Other Jurisdictions Instruct The Jurors On The Prosecution's Burden To Prove “Every Element” Or “Each Element”
Tuesday, April 5, 2011
Strategy Note: Consideration Of Whether Curative Instruction Will Highlight Prejudice
“Objections sometimes highlight the issue for the jury, and curative instructions always do. Particularly in a case such as this, where the general line of questioning concerning flight and post‑incident behavior was legitimate to rebut the justification defense, and only the proper temporal bound was crossed, counsel could believe that it was better not to call attention to the temporal limitation and to let his client explain himself. ” Commonwealth v. Colavita, 993 A.2d 874, 896 (Pa., No. 20 EAP 2008, 4/29/2010); see also Commonwealth v. Whitney, 550 Pa. 618, 708 A.2d 471, 478 (1998).
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Monday, April 4, 2011
Ineffective Assistance Of Counsel: Failure To Raise Jury Instruction Claim (Ohio)
In State v. Kent, 2010 Ohio 1851 (Ohio Ct. App., Cuyahoga County, No. 90795, Apr. 27, 2010) the judge failed to instruct the jurors with regard to the mens rea of recklessness as required by the Supreme Court of Ohio in State v. Colon, 118 Ohio St.3d 26, 2008 Ohio 1624, 885 N.E.2d 917. However, appellate counsel did not raise the issue on appeal and Kent filed an application for reopening an appeal which alleged ineffective assistance of appellate counsel. The claim was sustained: “We, . . . find that there exists a genuine issue as whether Kent was deprived of effective assistance of counsel on appeal, as a result of his conviction for the offense of aggravated robbery under R.C. 2911.02(A)(3). Kent has demonstrated that there exists a genuine issue as to whether an error in the indictment and the court's jury instruction, as to the mens rea of recklessness that is associated with the offense of aggravated robbery brought pursuant to R.C. 2911.01(A)(3), permeated the trial from beginning to end and placed into question the reliability of the trial court in serving its function as the mechanism for the determination of guilt or innocence. This issue was not raised on appeal by appellate counsel, and if raised, could have resulted in a different outcome on appeal. [Citation.]” State v. Kent, 2010 Ohio 1851, P24‑P26 (Ohio Ct. App., Cuyahoga County, No. 90795, Apr. 27, 2010).
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PG X(K) - Ineffective Assistance of Counsel On Appeal
Friday, April 1, 2011
Judge Has No Duty To Recite Language Of The Standard Pattern/Model Instructions (Ohio)
The trial judge is not required to provide the jury with a verbatim recitation of a requested jury instruction, such as any instruction contained within the Ohio Jury Instructions. State v. Kent, 2010 Ohio 1851, P10‑P26 (Ohio Ct. App., Cuyahoga County, No. 90795, Apr. 27, 2010); State v. Scott (1986), 26 Ohio St.3d 92, 26 Ohio B. 79, 497 N.E.2d 55; State v. Brady (1988), 48 Ohio App.3d 41, 548 N.E.2d 278. The trial court's jury instruction need only communicate to the jury, the legal principles and law pertinent to the case. State v. Sneed (1992), 63 Ohio St.3d 3, 584 N.E.2d 1160; State v. Nelson (1973), 36 Ohio St.2d 79, 303 N.E.2d 865.
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