Victor v. Nebraska
United States Supreme Court
511 U.S. 1 (1994)
Victor was convicted of murder in Nebraska and Sandoval was convicted of murder in California; both challenged their convictions, consolidated for Supreme Court review, on the ground that their trial courts' reasonable-doubt jury instructions -- which used phrases like "moral evidence" and "moral certainty," derived partly from a historic 1850 Massachusetts instruction -- improperly diluted the reasonable-doubt standard and violated due process. Victor's instruction defined reasonable doubt as "actual and substantial" doubt rather than doubt from mere possibility or conjecture, and also offered an alternative "hesitate to act" formulation; Sandoval's instruction used the state's own statutory definition tracing to the same historic source.
Whether a trial court's jury instruction violates a defendant's due process rights when it does not lead the jury to convict under a standard less stringent than reasonable doubt.