VICTOR V NEBRASKA - Victor v Nebraska United States Supreme...

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Victor v. Nebraska United States Supreme Court 511 U.S. 1 (1994) Rule of Law 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. Facts 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. 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? Holding and Reasoning (O’Connor, J.) No. 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). The Webster instruction came about at a time when the courts began to apply the reasonable doubt standard in its modern form and represents one of the most widely accepted definitions of reasonable doubt.

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