ICJI 103 (2010)
Idaho Criminal Jury Instructions
ICJI 100 PRE-PROOF INSTRUCTIONS
ICJI 103 REASONABLE DOUBT PRESUMPTION OF INNOCENCE-REASONABLE DOUBT
Under our law and system of justice, the defendant is presumed to be innocent. The presumption of innocence means two things.
First, the state has the burden of proving the defendant guilty. The state has that burden throughout the trial. The defendant is never required to prove [his] [her] innocence, nor does the defendant ever have to produce any evidence at all.
Second, the state must prove the alleged crime beyond a reasonable doubt. A reasonable doubt is not a mere possible or imaginary doubt. It is a doubt based on reason and common sense. It may arise from a careful and impartial consideration of all the evidence, or from lack of evidence. If after considering all the evidence you have a reasonable doubt about the defendant’s guilt, you must find the defendant not guilty.