In Holland v. United States, 348 U.S. 121 (1954), the United States Supreme Court addressed a trial judge's refusal to instruct the jury that where the government's evidence is circumstantial, it must exclude every reasonable hypothesis other than that of guilt. While there is support for the "reasonable hypothesis of innocence" instruction in lower courts, "the better rule is that where the jury is properly instructed on the standards for reasonable doubt, such an additional instruction on circumstantial evidence is confusing and incorrect." 348 U.S. at 139-40. The Court noted that the trial court had defined reasonable doubt as the kind of doubt jurors "might be willing to act" upon in the more serious and important affairs of their own lives. The Court stated that the trial court should have defined reasonable doubt as one that would cause a person to hesitate to act in the important affairs rather than cause them to be willing to act. Despite the Court's express preference for the hesitate to act language, it concluded that the reasonable doubt instruction, taken as a whole, correctly conveyed the concept of reasonable doubt. Id.