Also known as: beyond reasonable doubt · reasonable doubt
Written by attorneys — see sources below.
A standard of proof in criminal proceedings that requires the prosecution to establish every element of the charged offense to a degree of certainty that leaves no reasonable doubt in the mind of a rational factfinder. The standard protects the presumption of innocence by directing acquittal whenever the evidence permits a reasonable person to entertain doubt about guilt.
MetroBuild contracted to purchase land from O'Hara. A title search disclosed an apparently forged deed in the chain of title from twenty-five years earlier. MetroBuild refused to close. Because the forgery created a substantial risk that a third party held superior title, the defect left reasonable doubt about ownership and rendered the title unmarketable.
The government charged Oliver with conspiracy based on recorded conversations and expense reports that vendors described as ordinary hospitality. The materials permitted an equally plausible innocent interpretation. Because the evidence did not eliminate every reasonable doubt about the existence of a corrupt agreement, the district court should have granted the motion for judgment of acquittal.
Bernice was acquitted of homicide but the estate sought to disqualify her from an annuity under the slayer rule. In the probate proceeding the estate introduced an eyewitness account of the argument and Bernice's assault conviction. The civil court applied the preponderance standard and found Bernice responsible for the killing, because the criminal acquittal did not preclude a civil finding under the lower burden.
Bernard struck an assailant with a heavy object after the assailant lunged with a knife. The blow caused permanent loss of vision in one eye. Because the resulting harm differed in kind from ordinary bodily injury and carried a substantial risk of fatal consequences, the force used was not privileged under the self-defense privilege.
A fourteen-year-old was charged in juvenile court with acts that would constitute theft if committed by an adult. The only evidence consisted of ambiguous text messages and blurry surveillance images. Because the prosecution failed to prove every element beyond a reasonable doubt, due process required that the adjudication be vacated.
During a 1967 adjudicatory hearing conducted pursuant to section 742 of the New York Family Court Act, a judge in New York Family Court found that the twelve-year-old appellant had entered a locker and stolen one hundred twelve dollars from a woman's pocketbook. The petition which charged appellant with delinquency alleged that his act, if done by an adult, would constitute the crime or crimes of larceny. The judge acknowledged that the proof might not establish guilt beyond a reasonable doubt but relied on section 744(b) of the New York Family Court Act, which provides that any determination at the conclusion of an adjudicatory hearing that a juvenile did an act or acts must be based on a preponderance of the evidence. After a subsequent dispositional hearing, appellant was ordered placed in a training school for an initial period of eighteen months, subject to annual extensions of his commitment until his eighteenth birthday, six years in appellant's case. The Appellate Division of the New York Supreme Court, First Judicial Department, affirmed without opinion. The New York Court of Appeals then affirmed by a four-to-three vote, expressly sustaining the constitutionality of section 744(b). The Supreme Court noted probable jurisdiction.
View caseFisher was tried for first-degree murder. The trial court instructed the jury that the prosecution must prove purpose, malice, premeditation, and deliberation beyond a reasonable doubt. The instruction correctly required the government to satisfy the highest standard on each essential element before the jury could return a conviction.
In March 1944 petitioner Fisher, the janitor at the library of the Cathedral of Saint Peter and Saint Paul in Washington, D.C., killed librarian Catherine Cooper Reardon inside the library building between eight and nine o'clock on the morning of March 1. Reardon had complained a few days earlier to the verger about Fisher's care of the premises, and the verger had informed Fisher of the complaint. Fisher and Reardon were alone in the library at the time of the homicide. Fisher testified that Reardon spoke insulting words about his work, after which he slapped her impulsively. He ran up a flight of steps toward an exit but turned back, seized a stick of firewood, struck her, and when the stick broke choked her to silence. He then dragged her to a lavatory and left the body to clean up some spots of blood on the floor outside. While Fisher was doing this cleaning up, the victim started hollering again. Fisher then took out his knife and stuck her in the throat. After that he dragged her body down into an adjoining pump pit, where it was found the next morning. Fisher's accounts of the events varied. His original confession made no reference to insulting words from Reardon. His written confession mentioned them, and his trial testimony amplified their effect on him. In the written confession he admitted his main reason for assaulting her was that she had reported him for not cleaning the floor. The Deputy Coroner testified that the knife wound was not deep and only went through the skin. Defense psychiatrists testified that Fisher was a psychopathic personality of a predominantly aggressive type, mentally somewhat below average, with minor stigmata of mental subnormalcy, and that he was unable by reason of a deranged mental condition to resist the impulse to kill. The prosecution introduced competent evidence that Fisher was capable of understanding the nature and quality of his acts. All evidence offered by the defense was received by the trial court. Fisher was tried in the District Court of the United States for the District of Columbia on an indictment charging killing by choking and strangling with deliberate and premeditated malice. The jury returned a verdict of guilty on the first count, and the court imposed a sentence of death. The United States Court of Appeals for the District of Columbia affirmed the judgment and sentence.
View caseThe prosecution must prove every element of the offense beyond a reasonable doubt. Model Penal Code section 1.12(a) states that no person may be convicted unless each element is proved to that degree and that innocence is assumed in the absence of such proof.
Yes. Due process requires proof beyond a reasonable doubt when a juvenile is charged with conduct that would be criminal if committed by an adult, as held in In re Winship.
A civil proceeding to determine slayer status uses the preponderance standard rather than beyond a reasonable doubt. A final criminal conviction for intentional killing nevertheless conclusively establishes slayer status in the civil case.
A rational factfinder cannot conclude that guilt has been proved beyond a reasonable doubt. The court must therefore grant a motion for judgment of acquittal when the evidence leaves reasonable doubt about an essential element.
Yes. Any fact that increases a mandatory minimum sentence is an element that must be submitted to the jury and proved beyond a reasonable doubt.