Cage v. Louisiana

In Cage v. Louisiana, 498 U.S. 39, 111 S. Ct. 328, 112 L. Ed. 2d 339 (1990), the court held improper an instruction that equated a reasonable doubt with a "grave uncertainty" and an "actual substantial doubt" and stated that what was required was a "moral certainty that the defendant was guilty." Id. 112 L. Ed. 2d at 340. The Supreme Court of the United States reversed the petitioner's murder conviction, concluding that the trial court's jury instructions on the definition of reasonable doubt impermissibly diluted the state's burden of proof. In ruling that the trial court's jury instructions were constitutionally defective, the Supreme Court focused on the trial court's descriptions of reasonable doubt as such doubt as would give rise to a grave uncertainty, an actual substantial doubt and a moral certainty. Id., 112 L. Ed. 2d at 340. It is plain to us, the Supreme Court declared, that the words substantial and grave, as they are commonly understood, suggest a higher degree of doubt than is required for acquittal under the reasonable-doubt standard. When those statements are then considered with the reference to moral certainty, rather than evidentiary certainty, it becomes clear that a reasonable juror could have interpreted the instruction to allow a finding of guilt based on a degree of proof below that required by the Due Process Clause. Id., 112 L. Ed. 2d at 341.