By Marcus Fields
Is a Good Faith Jury Instruction Required if a Court has Already Given an Adequate Specific Intent Instruction?
Today in United States v. McCants, the Fourth Circuit made clear that it is within the discretion of a district court to refuse to give a good faith jury instruction as long as it has given an adequate specific intent instruction. Because the district court did not abuse its discretion, the Fourth Circuit affirmed McCants’ conviction of passing fictitious financial obligations.
Standard of Review for Jury Instructions
When reviewing jury instructions for potential error, the Fourth Circuit focuses on the adequacy of instruction “regarding the elements of the offense and the defendant’s defenses.” It will review the instructions “in their entirety” keeping the trial as a whole in mind. The Fourth Circuit will review de novo whether the court below “has properly instructed a jury on the statutory elements of an offense.” All other jury instruction decisions will be reviewed under an abuse of discretion standard.
When is a Court’s Refusal to Give a Jury Instruction a Reversible Error?
The Fourth Circuit reiterated that the refusal to give a jury instruction is reversible as an abuse of discretion when the proposed instruction meets three factors: (1) The instruction “was correct; (2) was not substantially covered by the court’s charge to the jury; and (3) dealt with some point in the trial so important, that failure to give the requested instruction seriously impaired the defendant’s ability to conduct his defense.”
Refusal to Give a Good Faith Jury Instruction was not an Abuse of Discretion.
The Fourth Circuit concluded “that the district court provided an adequate specific intent instruction to the jury.” Presumably because the good faith instruction was “substantially covered” by the specific intent instruction, the Fourth Circuit held that the district court was “not required to give an additional instruction on good faith.”
District Court Judgment Affirmed
The Fourth Circuit affirmed the judgment of the district court. It dispensed with oral arguments determining that they would not help the decisional process.