Also known as: reasonable doubt · beyond a reasonable doubt · beyond reasonable doubt · BRD
Written by attorneys — see sources below.
The prosecution's burden to establish every element of a charged offense to the factfinder's satisfaction before a conviction may be returned. The standard protects the presumption of innocence by requiring the government to eliminate reasonable uncertainty about the defendant's guilt.
The state charged Robert Rivera with theft. The trial judge instructed the jury that it could convict only if the prosecution proved every element of the offense beyond a reasonable doubt. The jury acquitted after finding a reasonable doubt on the element of intent.
The state charged Riley Rivera with theft. The trial judge instructed the jury that it could convict only if the prosecution proved every element of the offense beyond a reasonable doubt. The jury acquitted after finding a reasonable doubt on the element of intent.
Ronald Reed petitioned to bar Ruby Rivera from inheriting under their parent's will, alleging she feloniously killed the decedent. The probate court applied the preponderance standard rather than reasonable doubt and found Ruby to be the slayer after a civil trial.
Rina Rahman faced assault charges after striking an attacker. The trial judge instructed the jury that the prosecution must disprove the justification defense beyond a reasonable doubt. The jury acquitted after finding reasonable doubt that the force used was justified.
The state petitioned to adjudicate Robert Rivera delinquent for an act that would constitute larceny if committed by an adult. The family court applied the reasonable doubt standard to each element and dismissed the petition when the evidence left reasonable uncertainty about identity.
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 caseRegina Robinson moved to suppress a statement taken during custodial interrogation. The court applied the preponderance standard to admissibility at the suppression hearing while reserving the reasonable doubt standard for the jury's ultimate determination of guilt.
In March 1963 Ernesto Miranda was arrested at his home in Phoenix and taken to the police station where he was identified by the complaining witness. He was then questioned by two officers in Interrogation Room No. 2 for two hours. The officers did not advise him of any right to counsel. Miranda signed a typed confession that was introduced at his trial for kidnapping and rape. On October 14 1960 Michael Vignera was arrested in connection with a Brooklyn robbery. He was taken first to the 17th Detective Squad headquarters in Manhattan and later to the 66th Detective Squad. A detective questioned him for several hours without any advice concerning counsel. Vignera made an oral admission. He was then questioned by an assistant district attorney whose transcribed statement was also introduced at his trial for first-degree robbery. On March 20 1963 Carl Calvin Westover was arrested by Kansas City police as a suspect in two local robberies. Kansas City police interrogated Westover on the night of his arrest. The next day local officers interrogated him again throughout the morning. Westover was then turned over to FBI agents who questioned him for two to two-and-a-half hours about California robberies and obtained signed confessions. At the time the FBI agents began questioning Westover he had been in custody for over fourteen hours. On January 31 1963 Roy Allen Stewart was arrested at his home in connection with a series of purse-snatch robberies. During the next five days police interrogated Stewart on nine different occasions without any advice of rights. On the ninth session Stewart confessed. Transcripts of the interrogations were introduced at his trial for kidnapping rape and murder. The Arizona Supreme Court affirmed Miranda's conviction. The New York courts affirmed Vignera's conviction. The Ninth Circuit affirmed Westover's conviction. The California Supreme Court reversed Stewart's conviction. The Supreme Court granted certiorari in the four cases and consolidated them for argument.
View caseYes. The Due Process Clause requires proof beyond a reasonable doubt of every fact necessary to constitute the charged offense in juvenile adjudications as well as adult criminal trials.
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The defendant must be acquitted. The presumption of innocence remains in force and no conviction may be entered when reasonable doubt exists on any element of the offense.
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No. The slayer determination in a civil proceeding uses the preponderance of the evidence standard, although a final criminal conviction for intentional killing conclusively establishes slayer status.
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No. The prosecution need only prove the voluntariness of a confession by a preponderance of the evidence at a suppression hearing. The reasonable doubt standard applies only to the jury's determination of guilt.
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…values in law enforcement, although this is similarly true of other limitations such as the grand jury requirement and the reasonable doubt standard. Accusatorial values, however, have openly been absorbed into the due process standard governing confessions; this indeed is why at present "the kinship of the two rules [governing…