Washington v. Chacon

Petitioner John Chacon sought reversal of an unpublished Court of Appeals opinion affirming his conviction for second degree assault and criminal trespass. At trial, the judge instructed the jury on reasonable doubt, using 11 Washington Pattern Jury Instructions: Criminal 4.01, at 93 (4th ed. 2016) (WPIC), but omitted the last sentence of that instruction, which stated, "The defendant has no burden of proving that a reasonable doubt exists." Chacon failed to object to the instruction at trial, but argued the omission was a manifest constitutional error, which could be reviewed for the first time on appeal pursuant to RAP 2.5(a)(3). After review, the Washington Supreme Court found the instruction was not manifest constitutional error, and affirmed Chacon's conviction. View "Washington v. Chacon" on Justia Law