In United States v. Hayes, 794 F.2d 1348 (9th Cir. 1986), the Court upheld a conviction obtained after the district court had instructed the jury to find that the defendant had acted in good faith, which it defined, as did the district court in this case, to mean that the practitioner had made "an honest effort to prescribe for a patient's condition in accordance with the standard of medical practice generally recognized and accepted in the country." Id. at 1351. In Hayes, the Court observed that the district court's reference to the standard of medical care was potentially confusing and that "more precise language could have been used." Id. at 1352. The Court nonetheless affirmed the practitioner's conviction because, after viewing the jury instructions in their entirety, "we failed to see how the jury could have interpreted the instructions as permitting a finding of guilt based on mere negligence." Id.