People v. Aranda
Annotate this CaseDefendant was charged with two separate crimes, murder and participation in a criminal street gang. The court failed to include the standard reasonable doubt instruction prior to the jury's deliberations. The court's instructions with regard to the murder charge did inform the jury that it must find every element of that charge must be proved beyond a reasonable doubt. The instruction relating to the gang offense did not include similar reasonable doubt language. The jury found Defendant guilty of the lesser offense of voluntary manslaughter and of the gang offense. The court of appeals reversed Defendant's conviction of the gang offense. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court's omission of the standard reasonable doubt instruction did not constitute federal constitutional error as to the voluntary manslaughter conviction, and although the omission amounted to state law error as to that conviction, the error was harmless; and (2) with respect to the gang offense, the failure to instruct the jury to prove the elements of the crime beyond a reasonable doubt constituted error under both state law and the federal constitution, but the error was harmless.
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