A Book from the Library of Defense

Special Jury Instruction for Commercial Drug Offenses (Includes Sample and Memo)

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by: Ryan • April 19, 2012 • no comments

I have attached a special jury instruction for your use in CDO cases. I wrote it for a BM 57 drug case. The same logic may also apply to enhancement factors for burglary in the first degree and maybe even the gun minimum.

Very simple issue. How many jurors does it take to find those enhancements "not proven"?

The answer varies, but I can tell you it's not "10."

CDO-SQ Instruction