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The burden is upon the State to prove beyond a reasonable doubt that the Defendant is guilty of the crime(s) charged. It is a strict and heavy burden. The evidence must overcome any reasonable doubt concerning the Defendant's guilt. But it does not mean that a Defendant's guilt must be proved beyond all possible doubt.
This means that the prosecution must convince the jury that there is no other reasonable explanation that can come from the evidence presented at trial. In other words, the jury must be virtually certain of the defendant's guilt in order to render a guilty verdict.
Proof beyond a reasonable doubt means proof which is so convincing that you would not hesitate to rely and act on it in making the most important decisions in your own lives. If you are convinced that the Government has proved Defendant guilty beyond a reasonable doubt, say so by returning a guilty verdict.
606.31 BURDEN OF PROOF; REASONABLE DOUBT; SELF-DEFENSE. (a) Every person accused of an offense is presumed innocent until proven guilty beyond a reasonable doubt, and the burden of proof for all elements of the offense is upon the prosecution.
The judge issues their jury instructions at the end of a trial, once the prosecution and defense have presented all of their evidence and arguments.
A reasonable doubt is a doubt based upon reason and common sense and is not based purely on speculation. It may arise from a careful and impartial consideration of all the evidence, or from lack of evidence.
The Ohio Jury Instructions (OJI) are written by a committee of the Ohio Judicial Conference. The Law Library has the OJI in its Westlaw database, Lexis ebooks (Overdrive) as well as in print. You can buy Ohio Jury Instructions in print or electronically from LexisNexis.