BThomas_CRJ552_MOD5 (Victor v. Nebraska)
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CRJ 552
Criminal Advocacy & Judicial Procedure
Jury Selection (Voire Dire) and Opening Statements
TITLE AND CITATION
:
Victor v. Nebraska, 511 U.S. 1 (1994)
TYPE OF ACTION
: Review by the U.S. Supreme Court of a lower court ruling related to the
constitutionality of two different sets of jury instructions defining the terms of “reasonable doubt” in
two distinct cases.
FACTS OF THE CASE
:
Sandoval was accused of shooting three men, two of them fatally during what was determined to
be a gang-related shooting.
Approximately two weeks after the shooting the Petitioner killed an
individual who he believed that provided information to the police that resulted in his conviction.
The petitioner also then killed the individual’s wife. The petitioner was ultimately convicted on four
counts of first-degree murder. A sentence of death for the murder of the wife, and life in prison for
the murder of three other individuals was handed down.
The California Supreme Court affirmed
the convictions and sentences, with the jury being offered the following instructions surrounding
reasonable doubt “it is not a mere possible doubt; because everything relating to human affairs,
and depending on moral evidence, is open to some possible or imaginary doubt.
The California
Court ruled that the reasonable doubt portion of jury instructions was presented in appropriate
manner.
Victor murdered an eighty-two-year-old woman.
He was ultimately convicted of first-degree
murder and was sentenced to death, with the Nebraska Supreme Court affirming his conviction.
The judge in his presentation of jury instructions stated that the burden of proof is always on the
side of the state to prove beyond a reasonable doubt that material elements of the crime charged
and that this burden never shifts to the defense.
Victor (defendant) was convicted of murder in the state of Nebraska (plaintiff). Sandoval was
convicted of murder in the state of California. Both defendants appealed their convictions on
grounds that the trial court’s jury instructions conveyed an improper definition of the reasonable
doubt standard and violated the defendants’ due process rights. The United States Supreme
Court consolidated the two cases for review.
CONTENTIONS OF THE PARTIES:
Victor:
Victor argues that equating the concept of “reasonable doubt” with that of “substantial
doubt” overstates the degree of doubt which would in turn be necessary for jury to offer an
acquittal of charges presented against a defendant.
Nebraska:
The state of Nebraska argued that there were no contentions that due process was
violate by the instructions provided in how the term’s of “reasonable doubt” were defined by the
court in presentation to the jury.
ISSUE:
Does a trial court’s jury instruction violate a defendant’s due process rights when it does
not lead the jury to convict under a standard less stringent than reasonable doubt?
DECISION:
No.
REASONING:
A trial court’s jury instruction does not violate a defendant’s due process rights
when it does not lead the jury to convict under a standard less stringent than reasonable doubt. In
Sandoval’s case, the trial court delivered a jury instruction based upon the state’s statutory
definition of reasonable doubt. That definition is derived from an instruction delivered by the
Massachusetts Supreme Judicial Court in Commonwealth v. Webster¸ 59 Mass. 295, 320 (1850).
RULE OF LAW:
The Constitution does not offer instructions related specifically to how the court
instructions must be worded when presented to the jury in correlation with the terms of doubt.
As
long as instructions are provided to the jury that sufficiently explain the necessity that the
defendants guilt be found beyond a reasonable doubt, they are sufficient. Reviewed in its entirety
the instructions must be sufficient in conveying the true meaning of “reasonable doubt” to the jury.
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