Criminal Jury Instructions for the District of Columbia
Fifth Edition (2014)
II. FINAL INSTRUCTIONS
Instruction 2.107. BURDEN OF PROOF—PRESUMPTION OF INNOCENCE
Every defendant in a criminal case is presumed to be innocent. This presumption of innocence remains with the defendant throughout the trial unless and until the government has proven s/he is guilty beyond a reasonable doubt. This burden never shifts throughout the trial. The law does not require [name of defendant] to prove his/her innocence or to produce any evidence at all. If you find that the government has proven beyond a reasonable doubt every element of [the] [a particular] offense with which [name of defendant] is charged, it is your duty to find him/her guilty [of that offense]. On the other hand, if you find the government has failed to prove any element of [the] [a particular] offense beyond a reasonable doubt, it is your duty to find [name of defendant] not guilty [of that offense].