📄 Motion: jury instruction objections — Friday, September 22, 1995
Address:
C:\DEPT103\CRIMINAL\1995\SEP\22\MOTION-JURY-INSTRUCTION-OBJECT.DOC
TRIAL
▲ Day 160 of 167

Motion: jury instruction objections

Date: Friday, September 22, 1995 • Utterances: 15
Judge Ito placed on the record the results of an off-the-record chambers conference settling jury instructions. The Prosecution formally withdrew two theories — implied malice second-degree murder and lying-in-wait premeditation — and the court agreed to add language on DNA laboratory error rates to its special instruction. Defense counsel Uelmen then entered a series of formal objections for the record, including disputes over chain-of-custody instruction language, Ron Shipp admission instructions, defendant demeanor evidence, and a request that the jury be told Fuhrman is an 'unavailable witness.'
1 THE COURT:

All right. Back on the record in the Simpson matter. Mr. Simpson is again present before the court with his counsel--let's have it quiet in the courtroom, please. Mr. Simpson is present before the court with his counsel, Mr. Shapiro, Mr. Cochran, Mr. Blasier, Mr. Neufeld, Mr. Uelmen. The People are represented by Miss Clark, Mr. Darden and Mr. Kelberg. The jury is not present. The record should reflect that the court has conducted an off-the-record in chambers conference with counsel to conclude our discussions concerning the jury instructions. And so that the record is clear, the Prosecution has withdrawn their request for instruction 8.31, second degree murder on an implied malice theory. They have withdrawn that. They have also withdrawn 8.25, murder by means of lying in wait as a theory of premeditation. The record should reflect that the court has modified 2.20 at the request of the Defense to include any influence that might be exerted upon a witness at the time of their testimony by any drug, alcohol or other substance. The court has heard argument in chambers regarding the DNA instruction that the court intends to give, and I've heard the argument regarding the request that the court instruct on a laboratory error rate as a phenomena that should be considered by the jury. Any other comment on that particular issue? Is the matter submitted?

2 MS. CLARK:

Submitted.

3 MR. KELBERG:

Submitted, your Honor.

4 MR. UELMEN:

Submitted.

5 MR. COCHRAN:

Mr. Scheck.

6 THE COURT:

All right. I have contemplated this issue. This is unfortunately an area where instructions from other courts, and approved by the court of appeal in various states, there is not an overabundance of guidance to the trial court. I believe that the--the argument that laboratory error rates should be considered is a valid argument and I will instruct--I will include the following two sentences on the court's special instruction no. 3: "frequency estimates in laboratory error rates of different phenomena both should be considered in determining what significance to attach to bloodstain testing results." All right. Any other comment on instructions before we invite the jurors to join us? Mr. Uelmen?

7 MR. UELMEN:

For the record, your Honor, with respect to the rulings that we were informed of this morning, we would like to reiterate our objection to the special instruction that the court proposes to give on section 403 of the evidence code. We believe that giving this instruction will be prejudicial error because it deprives the Defendant of a factual determination by the jury of the chain of custody issue to which he is entitled under section 403 of the evidence code. And I know your Honor noted, in denying our pretrial motion challenging the admission of the evidence from the Bronco, that chain of custody would be an issue for the jury to consider, but we believe that this instruction deprives us of a jury determination of that issue by submitting it to them just in general terms of relevancy, rather than requiring a finding of the preliminary fact that a chain of custody was observed. Secondly, we want to object to the court giving section 271 and 272. We believe this highlights the prejudice to the Defendant in the admission of the Ron Shipp testimony, since the court has indicated this is the only basis on which the jury will be instructed that they can find an admission by the Defendant.

8 THE COURT:

I don't think that is correct. I indicated that Mr. Kelberg's argument that statements made by a Defendant that are later shown to be untrue or in some way assist the Prosecution, those are legally defined as admissions.

9 MR. UELMEN:

Even if they refer to the prior similar acts admitted under section 1101?

10 THE COURT:

No, there are other comments.

11 MR. UELMEN:

We--we further object to the denial of the court--by the court of the proposed instruction D-33 relating to the demeanor of the Defendant. Your Honor indicated that you thought the reasonable doubt instruction would cover that.

12 THE COURT:

Reasonable doubt, burden of proof.

13 MR. UELMEN:

We believe that the Defendant is entitled to an instruction with respect to his theory of the case and the demeanor evidence was a very important part of the Defense's theory of the case. And finally, we would like to make one more request, that the court at least instruct the jury that Detective Mark Fuhrman is an unavailable witness, without any comment as to any conclusions to be drawn from that fact. We believe this Defense is significantly prejudiced by the jury being sent out to decide this case without any information as to what became of Detective Fuhrman.

KEY QUOTE
14 THE COURT:

All right. Thank you, counsel. Mr. Kelberg, any response?

15 MR. KELBERG:

Yes, your Honor. Again, I don't think there is any basis to highlight that, no. 1. No. 2, I don't think anyone is going to argue, from the Prosecution perspective, the failure of the Defense to bring back Detective Fuhrman in any way is going to strengthen the inference of guilt in this matter. The credibility issue is obviously there and no one is going to hide from it. With respect to the other requests by Dean Uelmen, obviously I agree with the court's ruling on D-33. I don't think I need comment on that. I think the record should reflect that because we have withdrawn a theory of implied malice for second degree murder, that we have asked the court to conform other instructions, that, for example, 3.31 as modified to strike any reference to implied malice wherever it may appear and I think has indicated it was going to do so in those additional instructions. With respect to the Fuhrman matter, one last point is I believe legally that it violates the evidence code provision which I do not believe is unconstitutional as applied to a witness. To have an adverse inference drawn from the proper invocation of a privilege and to tell the jury about unavailability invites speculation instead of staving off speculation, so I would request the court to keep the record as it is on the jury instructions with respect to Mr. Fuhrman and have the general instructions apply. Thank you, your Honor.

Temperature

procedural

Key Quotes (4)

Lance A. Ito
frequency estimates in laboratory error rates of different phenomena both should be considered in determining what significance to attach to bloodstain testing results.
The court's special instruction language on DNA lab error rates — a significant win for the defense, compelling jurors to weigh error rates alongside frequency statistics.
Gerald Uelmen
We believe that the Defendant is entitled to an instruction with respect to his theory of the case and the demeanor evidence was a very important part of the Defense's theory of the case.
Defense formally preserves the argument that Simpson's courtroom demeanor was substantive exculpatory evidence the jury should have been directed to consider.
Gerald Uelmen
We would like to make one more request, that the court at least instruct the jury that Detective Mark Fuhrman is an unavailable witness, without any comment as to any conclusions to be drawn from that fact.
Defense presses for the jury to know Fuhrman invoked the Fifth Amendment and is gone — framing it as a fairness issue without asking for an explicit adverse inference.
Brian Kelberg
To have an adverse inference drawn from the proper invocation of a privilege and to tell the jury about unavailability invites speculation instead of staving off speculation.
Prosecution's counter-argument: telling jurors Fuhrman is 'unavailable' would itself inject prejudicial speculation, and general instructions suffice.

Evidence (3)

Informal
DNA bloodstain testing results — lab error rates and frequency estimates
Discussed; court adds two-sentence lab error rate language to special instruction no. 3
Informal
Bronco blood evidence — chain of custody challenge
Referenced in objection; Defense argues §403 instruction improperly converts chain-of-custody into a general relevancy question
Informal
Ron Shipp testimony — statements treated as admissions by defendant
Referenced in objection; Defense argues §271/272 instructions highlight prejudice from Shipp's testimony as the sole basis for admission instructions

Notable Exchanges (2)

Gerald UelmenLance A. Ito
Uelmen argues the §271/272 admission instructions unfairly single out the Shipp testimony; Ito pushes back, noting other defendant statements also qualify as admissions, including statements later shown to be untrue.
strategic
Gerald UelmenBrian Kelberg
Uelmen requests a bare-bones Fuhrman unavailability instruction; Kelberg opposes on evidentiary privilege grounds, arguing it would invite exactly the speculation the Defense claims to want to avoid.
strategic

Credibility Attacks (1)

⚔ Mark Fuhrman
Unavailability / Fifth Amendment invocation
Defense argues jury should be formally told Fuhrman is unavailable, implicitly surfacing that he refused to testify; Prosecution successfully argues against any such instruction.

Objections

4 objections (0 sustained, 4 overruled)
Proceeding 7804 • 15 utterances
Criminal Trial
Department 103
⚖️ Start
📂 SEP 22, 1995 📄 Motion: jury instruction objec
SEP 22, 1995 KRT DvH TD