The Oyez Project: Criminal Procedure Issues - Jury Instructions Decisions

Arthur Andersen LLP v. United States

Did the jury instructions in the Arthur Andersen trial properly convey the elements of a "corrupt persuasion" conviction under federal document-handling law?

No. In a unanimous opinion delivered by Chief Justice William H. Rehnquist, the Court held that the jury instructions failed to convey that the federal document law required a "consciousness of wrongdoing" for conviction. There was nothing inherently corrupt in ordering employees to destroy documents, even if the aim was to keep the documents from the government. Thus, contrary to what the jurors had been told, Andersen could be convicted only if the persuaders were shown to be conscious that they were behaving corruptly.

California v. Brown

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Carella v. California

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Connecticut v. Johnson

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Cupp v. Naughten

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Estelle, Warden v. Mcguire

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Francis v. Franklin

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Frazier v. Cupp

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Gibson v. Lockheed Aircraft Co.

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Henderson v. Kibbe

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James v. Kentucky

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Jenkins v. United States

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Johnson v. Bennett

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Kelly v. South Carolina

Did the state trial court err in holding Simmons v. South Carolina, 512 U.S. 154 inapposite in the death sentence proceeding of William Kelly?

Yes. In a 5-4 opinion delivered by Justice David H. Souter, the Court held that Kelly was entitled to a jury instruction that he would be ineligible for parole under a life sentence. The Court reasoned that the Simons rule was applicable because under South Carolina's sentencing scheme, although a defendant charged with murder carrying the possibility of a death sentence could receive a sentence less than life imprisonment, a jury's only alternatives were to recommend death or life without parole, if the jury found the existence of an aggravating circumstance. Moreover, the Court found that the assertion that the defendant's future dangerousness was not at issue was unsupportable on the record.

Kentucky v. Whorton

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Koehler v. Engle

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Middleton v. McNeil

Were the instructions given to the jury in McNeil's trial sufficiently misleading to warrant the reversal of her sentence?

No. In a per curiam (unsigned) opinion, the Court ruled that the judge had provided correct instructions for three other parts of the instruction that were closely related to the error, and that, given the clarity of those instructions, the jury was unlikely to have been mislead by the four words erroneously inserted at the end. "Given three correct instructions and one contrary one, the state court did not unreasonably apply federal law when it found that there was no reasonable likelihood the jury was misled."

Neder v. United States

Does the District Court's omission of the element of materiality from a jury instruction on tax fraud constitute harmless error? Is materiality an element of federal mail, wire, and bank fraud?

Yes and Yes. In an opinion delivered by Chef Justice William H. Rehnquist, the Court held 6-3 that under the harmless-error rule, which applies to a jury instruction that omits an element of an offense, the trial court's error did not render Neder's trial "fundamentally unfair." Thus, the error was harmless. In dissent, Justices Antonin Scalia, David H. Souter, and Ruth Bader Ginsburg argued that depriving a criminal defendant of the right to have a jury determine his commission of every element of the crime charged could not constitute a harmless error. Additionally, the Court unanimously held that materiality is an element of federal mail fraud, wire fraud, and bank fraud.

Rose v. Clark

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Sandstrom v. Montana

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Sansone v. United States

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Shafer v. S. Carolina

Did the South Carolina Supreme Court properly hold Simmons v. South Carolina inapplicable to the state's current sentencing regime?

No. In a 7-2 opinion delivered by Justice Ruth Bader Ginsburg, the Court held that "whenever future dangerousness is at issue in a capital sentencing proceeding under South Carolina's new scheme, due process requires that the jury be informed that a life sentence carries no possibility of parole." Justice Ginsburg wrote that "[i]t is only when the jury endeavors the moral judgment whether to impose the death penalty that parole eligibility may become critical. Correspondingly, it is only at that stage that Simmons comes into play, a stage at which South Carolina law provides no third choice, no 30-year mandatory minimum, just death or life without parole." Justices Antonin Scalia and Clarence Thomas filed dissenting opinions.

Shannon v. United States

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Simmons v. South Carolina

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Spencer v. Texas

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Sullivan v. Louisiana

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Taylor v. Kentucky

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United States v. Bishop

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Victor v. Nebraska

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Weeks v. Angelone

Is the Constitution's due process requirement violated when a trial judge directs a capital jury's attention to a specific paragraph of a constitutionally sufficient instruction in response to a question regarding the proper consideration of mitigating circumstances?

No. In a 5-4 opinion delivered by Chief Justice William H. Rehnquist, the Court held that the Constitution was not violated by the Virginia trial judge who, during a capital trial's penalty phase, directed the jury's attention to the allegedly ambiguous paragraph of the jury's instruction in response to the jury's question as to mitigating evidence. "Given that petitioner's jury was adequately instructed, and given that the trial judge responded to the jury's question by directing its attention to the precise paragraph of the constitutionally adequate instruction that answers its inquiry, the question becomes whether the Constitution requires anything more," wrote Chief Justice Rehnquist, "[w]e hold that it does not." Writing for the dissenting minority, Justice John Paul Stevens argued that "[t]he record in this case establishes, not just a 'reasonable likelihood' of jury confusion, but a virtual certainty that the jury did not realize that there were two distinct legal bases for concluding that a death sentence was not 'justified.'"

Yates v. Evatt

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