The Oyez Project: Criminal Procedure Issues - Jury Instructions

Arthur Andersen LLP v. United States

As Enron's financial difficulties became public in 2001, Arthur Andersen instructed its employees to destroy Enron-related documents. This was consistent with Andersen's document retention policy. The government later charged Andersen for violating federal law, which made it a crime to "knowingly...corruptly persuade another person" to "withold" or "alter" documents in an "offical proceeding." The federal jury found Andersen guilty. The company appealed, arguing the jury instructions failed to convey the elements of a "corrupt persuasion" conviction - specifically, that a "consciousness of wrongdoing" was required. The Fifth Circuit affirmed the conviction.

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

After convicting William Kelly for murder, a South Carolina jury was asked to determine whether any aggravating factors had been shown and, if so, to recommend a sentence of death or life imprisonment. During sentencing, the prosecutor presented testimony that Kelly had taken part in an escape attempt with plans to hold a female guard hostage; provided evidence of Kelly's sadism and his desires to kill anyone who irritated him; and spoke of Kelly as a "butcher," "bloody," and "dangerous." Relying on the holding of Simmons v. South Carolina, 512 U.S. 154, that when "a capital defendant's future dangerousness is at issue, and the only sentencing alternative to death...is life imprisonment without possibility of parole, due process entitles the defendant 'to inform the jury of [his] parole ineligibility,'" Kelly's counsel requested a jury instruction stating that Kelly would be ineligible for parole if he received a life sentence. In refusing, the trial court said that the State's evidence went to Kelly's character and characteristics, not to future dangerousness. The jury recommended a death sentence. In affirming the sentence, the State Supreme Court held Simmons inapposite because state law provided the jury with a third sentencing alternative and future dangerousness was not at issue.

Kentucky v. Whorton

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Koehler v. Engle

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Middleton v. McNeil

Sally Marie McNeil was convicted of the murder of her husband. She appealed her conviction, claiming that the trial judge had given the jury improper instructions when it was deciding whether to convict her of murder or voluntary manslaughter (the last four words of the instruction, not included in the model jury instruction provided with the criminal statute, might have led the jury to misunderstand the meaning of voluntary manslaughter). The California Court of Appeal acknowledged that the jury instruction had been wrong, but found that, taken as a whole, the instruction did not make it reasonably likely that the jury would misunderstood the meaning of voluntary manslaughter, especially given the closing statements of the prosecutor, which provided the correct definition of the law.

McNeil then petitioned for a writ of habeas corpus in federal court. The district court rejected her claim, but a Ninth Circuit Court of Appeals panel reversed.

Neder v. United States

In the mid-1980's, Ellis E. Neder, Jr., engaged in a number of real estate transactions financed by fraudulently obtained bank loans and schemes involving land development fraud. He was indicted on numerous counts of federal mail fraud, wire fraud, bank fraud and of filing false federal income tax returns. At trial, the District Court instructed the jury that, to convict on the bank and tax offenses, it did not need to consider the materiality of any false statements, or whether Neder's actions, in fact, caused others to be defrauded. In instructing the jury on mail and wire fraud, the court did not include materiality as an element of either offense. Neder objected. Thereafter, Neder was convicted of filing false federal income tax returns and of federal mail fraud, wire fraud, and bank fraud. In affirming, the Court of Appeals held that the court erred in failing to submit the materiality element of the tax offense to the jury. However, under harmless-error analysis, the appeals court concluded the error was harmless because the error "'did not contribute to the verdict obtained." The appeals court also determined that materiality is not an element of mail fraud, wire fraud, and bank fraud. Thus, the District Court did not err in failing to submit materiality to the jury.

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

Wesley Aaron Shafer, Jr., was found guilty of murder, among other things. During the sentencing phase, Shafer's counsel argued that Simmons v. South Carolina required the trial judge to instruct the jury that under South Carolina law a life sentence carries no possibility of parole. The U.S. Supreme Court held in Simmons that where a capital defendant's future dangerousness is at issue, and the only sentencing alternative to death available to the jury is life imprisonment without possibility of parole, due process requires that the jury be informed of the defendant's parole ineligibility. The prosecution responded that because the state did not plan to argue to the jury that Shafer would be a danger in the future that no Simmons instruction was required. During deliberations, the jury asked under what conditions someone convicted of murder could become available for parole. The trial judge stated that parole eligibility or ineligibility was not a matter for the jury's consideration. Ultimately, the jury recommended the death penalty and the judge imposed the sentence. In affirming, the South Carolina Supreme Court held that Simmons generally did not apply to the State's sentencing scheme because an alternative to death other than life without the possibility of parole exists.

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

Lonnie Weeks, Jr., was found guilty of capital murder in the death of Virginia State Trooper Jose Cavazos. During the penalty phase of his trial, the prosecution sought to prove two aggravating circumstances. Weeks' defense presented 10 witnesses in mitigation. During deliberations, the jurors sent the trial judge a note asking whether, if they believed Weeks guilty of at least one of the aggravating circumstances, it was their duty to issue the death penalty, or whether they must decide whether to issue the death penalty or a life sentence. In responding, the trial judge only referred the jury to their instructions, which stated: "If you find from the evidence that the Commonwealth has proved, beyond a reasonable doubt, either of the two [aggravating circumstances], and as to that alternative, you are unanimous, then you may fix the punishment...at death, or if you believe from all the evidence that the death penalty is not justified, then you shall fix the punishment...at life imprisonment." The defense counsel objected, arguing for the judge to instruct the jury it could find one or both of the aggravating circumstances and still impose a life sentence. In finding one of the aggravating circumstances and after considering the evidence in mitigation, the jury returned a unanimous verdict fixing Weeks' punishment at death. On appeal to the Virginia Supreme Court, Weeks' presented 47 assignments of error, of which his assignment of error respecting the judge's answering the jury's question about mitigating circumstances was number 44. The court affirmed Weeks' conviction and sentence. Weeks' petition for federal habeas relief was ultimately denied.

Yates v. Evatt

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