THE SHELLOW COLLECTION
Jury Instructions By James M. Shellow of Wisconsin
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Defendant’s Plea

    1.    Plea Of Not Guilty Is A Denial Of Every Material Allegation Of Charge
    2.    Defendant's Response To Charges Is Not Evidence

THE SHELLOW COLLECTION
Jury Instructions By James M. Shellow of Wisconsin

1.     Plea Of Not Guilty Is A Denial Of Every Material Allegation Of Charge

ALERT: Carefully review the Caveats and Disclaimers before using these materials.

    To this charge in the [complaint] [information] the defendant has entered a plea of not guilty which means a denial of every material allegation in the [complaint] [information].

See generally NCJIC 270.2 [.Presumption Of Innocence - Prosecution Burden To Prove Guilt].

See NCJIC 270.2.14 [.Improper To Instruct That Plea Of Not Guilty Constitutes A Denial Of Every Material Allegation In The Charges].

THE SHELLOW COLLECTION
Jury Instructions By James M. Shellow of Wisconsin

2.    Defendant's Response To Charges Is Not Evidence

ALERT: Carefully review the Caveats and Disclaimers before using these materials.

    In response to the criminal complaint, which charges (him/her) with _____ crime(s), __________ (name of defendant) has informed the Court formally that (he/she) is not guilty of these crimes, because (he/she) contends that the facts are not as the state alleges. Both the state's charge in the complaint and __________’s (name of defendant) response to it merely are formal matters to define the issues for you, and neither are any evidence. Their only effect is to allow a trial and to raise the presumption that __________ (name of defendant) is innocent.

United States v. Greene, Criminal No. 92-32 (S.D. Iowa 1992).

See generally NCJIC 270.2 [.Presumption Of Innocence - Prosecution Burden To Prove Guilt].

See NCJIC 270.2.14 [.Improper To Instruct That Plea Of Not Guilty Constitutes A Denial Of Every Material Allegation In The Charges].