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Jury Instructions
Proposed Jury Instruction Threat with Citation-Post Counterman v. Colorado 2023
WPIC 2.24 was “corrected” by the Pattern Jury Instruction Committee Post Counterman v. Colorado. However, they merely added the required reckless standard for the speaker to the existing WPIC, which already had the obj...
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Proposed Jury Instruction-Knowledge with Citations
WPIC 10.02 is not accurate & insufficient to convict per the Washington State Supreme Court. Additionally, it is Misconduct for the State to argue it is sufficient to have constructive knowledge to convict, which is all that t...
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Motion for Juvenile/Young Adult Specific Jury Instruction (08.2019)
Based upon scientific research and landmark cases recognizing that children and young adults are different, the defense proposes juvenile or young adult specific jury instructions. Thanks to Ryan McGowan, WDA Legal Extern, 3L.
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Eye Witness ID:Out of Court ID
This jury instruction educates the jurors about circumstances that may impact the accuracy of eye witness ID. Thanks to Jim Koenig.
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Eye Witness ID _ In Court Only
This jury instruction educates the jurors about circumstances that may impact the accuracy of eye witness ID. Thanks to Jim Koenig.
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Eye Witness ID:In and Out of Court
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Mtn to Bifurcate Instructions-Aggravator
Motion/Memorandum to Bifurcate Instructions for Vulnerable Victim Aggravator
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Lesser Included: Murder 2 Lesser of Murder 1
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Assault 4 Jury Istructions
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