Coffin v. United States – Case Brief Summary (U.S. Supreme Court)

In Coffin v. United States (1895) 156 U.S. 432, a trial court refused a defense request to include an instruction that "'the law presumes that persons charged with crime are innocent . . . . ,'" and its reasonable doubt instruction included this language:

"If, after weighing all the proofs and looking only to the proofs, you impartially and honestly entertain the belief that the defendants may be innocent of the offences charged against them, they are entitled to the benefit of that doubt and you should acquit them." (Coffin, at p. 453.)

The Supreme Court, dealing with an alleged false entry in the books of a national bank, stated that "however wrongful may have been the bank president's previous acts, the making of an exact and truthful record of the same in the books of the bank was and could be no crime, under this statute".

The Court added, "we think it is clear that the making of a false entry is a concrete offense, which is not committed where the transaction entered actually took place, and is entered exactly as it occurred".

The Supreme Court faulted a trial court for declining to instruct the jury as to the presumption of innocence and then instructing:

"'If, after weighing all the proofs and looking only to the proofs, you impartially and honestly entertain the belief that the defendants may be innocent of the offences charged against them, they are entitled to the benefit of that doubt, and you should acquit them.'" (Id. at p. 453.)

This combination of a refusal to inform the jury of the presumption of innocence and an instruction focusing only on "'the proofs'" was erroneous. (Id. at p. 461.)

The Supreme Court concluded the presumption of innocence is distinct from the doctrine of reasonable doubt and that the trial court erred by failing to instruct on the former.

The court held the presumption of innocence to be a presumption of law in favor of the accused. The trial court's reasonable doubt instruction advised the jurors about "'weighing all the proofs and looking only to the proofs.'" (Coffin, supra, 156 U.S. at p. 461.)

However, the trial court had expressly refused to include the presumption of innocence among those proofs. This instruction confined the jurors to those matters that were admitted to their consideration by the court. The Supreme Court deemed the instruction erroneous, reversed the judgment, and remanded the case with directions to grant a new trial. (Id. at pp. 460-463.)

While the reasonable doubt instruction in Coffin did employ the phrases "'weighing all the proofs'" and "'impartially and honestly entertain the belief'" (Coffin, supra, 156 U.S. at p. 461), that language was not the basis upon which the Supreme Court found it inadequate.

The Supreme Court found the instruction inadequate because it omitted any reference to the presumption of innocence.

The focus of the opinion was on the necessity of including presumption of innocence and not the doctrine of reasonable doubt.

The Supreme Court ruled that the combination of the refusal to instruct the jury of the presumption of innocence and the instruction limiting consideration to "the proofs" had resulted in error for the following reason: "'The proofs and the proofs only' confined the jurors to those matters which were admitted to their consideration by the court, and among those elements of proof the court expressly refused to include the presumption of innocence, to which the accused was entitled, and the benefit whereof both the court and the jury were bound to extend him." (Id. at p. 461.) In other words, a court cannot tell a jury that they are limited to certain matters and then not include the presumption of innocence within those matters.

The trial court refused the defendant's request for an instruction on the presumption of innocence. (Id. at p. 452.) However, it did instruct that the jury had to find the defendants guilty beyond a reasonable doubt. (Ibid.) It further instructed that "'if, after weighing all the proofs and looking only to the proofs, you impartially and honestly entertain the belief that the defendants may be innocent of the offences charged against them, they are entitled to the benefit of that doubt, and you should acquit them.'" (Id. at p. 453.)

The Supreme Court held that the presumption of innocence and the requirement of proof beyond a reasonable doubt are distinct concepts, and hence the refusal to instruct on the presumption of innocence was error. (Coffin v. United States, supra, 156 U.S. at pp. 458-461.) It specifically declined to hold that the reasonable doubt instructions, in themselves, were erroneous. (Id. at p. 461.)