This blog will discuss a trial judge giving proper jury instructions.
To begin, jury instructions are the set of legal rules a judge reads to a jury for the jurors to follow when deciding a case. Regarding jury instructions, the instructions “must include all elements of the charged offenses and any material issues, defenses, and theories if supported by the evidence.” A mistake with jury instructions, in itself, is not grounds for setting aside a conviction if the issues were fairly presented.
In a recent Michigan Court of Appeals case, People v. William Lyles, Jr., a defendant was convicted of first-degree murder. On appeal, the defendant raised a claim regarding error related to the trial court’s jury instructions. Specifically, the defendant claimed the court failed to instruct the jury on the use and significance of his good character evidence. The jury instruction should have read:
(1) You have heard evidence about the defendant’s character for [peacefulness/honesty/good sexual morals/being law-abiding/(describe other trait)]. You may consider this evidence, together with all the other evidence in the case, in deciding whether the defendant committed the crime with which (he/she) is charged. Evidence of good character may sometimes create a reasonable doubt in your minds and lead you to find the defendant not guilty.
The Court of Appeals found that the instruction which the Court did read did not “substantially cover” defendant’s requested instruction. It did not adequately protect defendant’s rights or fairly present the importance of character evidence to the jury. Importantly, it did not advise the jury that evidence of good character alone may be sufficient to establish a reasonable doubt in the minds of the jurors.
The Court ultimately held that the denial of defendant’s request for an instruction on character evidence, where defendant presented evidence relating to his peaceful character, constituted a miscarriage of justice requiring reversal of the conviction and remand for a new trial. This was primarily based on the fact that there was minimal evidence that defendant committed the murder and the defense presented evidence related to defendant’s peacefulness.
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