Taylor v. Kentucky

In Taylor v. Kentucky, 436 U.S. 478 (1978), the prosecutor's closing argument described the beyond a reasonable doubt standard "by declaring that petitioner, 'like every other defendant who's ever been tried who's in the penitentiary or in the reformatory today, has this presumption of innocence until proved guilty beyond a reasonable doubt.'" 436 U.S. at 486. The court condemned the prosecution's argument because it linked the defendant to every defendant who turned out to be guilty and was sentenced to imprisonment. Id. at 486-87. The court further stated that the prosecutor's statement could be viewed as an invitation to the jury to consider defendant's status as a defendant as evidence tending to prove his guilt. Id. at 487. The United States Supreme Court determined whether the trial court should have instructed the jury on the presumption of innocence. The court noted that, unlike a legal scholar, who may understand the presumption of innocence and the prosecution's burden of proof as logically similar, the layperson may draw significant additional guidance from a presumption-of-innocence instruction. The court further noted that the instruction is one way of impressing upon the jury the importance of the criminal defendant's right to have his case determined solely upon the evidence presented at trial, and not upon other inappropriate grounds, including the defendant's indictment and his continued custody. (Taylor v. Kentucky, supra, 436 U.S. at page 485.) Under the facts in that case, the Supreme Court rejected the People's argument that no additional presumption-of-innocence instruction is necessary when a court already instructs the jury on the prosecution's burden of proof. After initially pointing out the inadequacies of the reasonable doubt instruction, the court explained, "even if the instruction on reasonable doubt had been more clearly stated, the People's argument ignores both the special purpose of a presumption-of-innocence instruction and the particular need for such an instruction in this case." The court, therefore, held that, under the circumstances, the court's denial of the defendant's requested instruction violated his right to a fair trial under the due process clause of the Fourteenth Amendment. (Taylor v. Kentucky, supra, 436 U.S. at page 490.)