Taylor v. Kentucky

Background

A man was tried in Kentucky for robbery after the victim said the defendant forced his way into the home and stole a billfold and a house key. The only witness was the victim; the defendant testified he was elsewhere. During trial the prosecutor read the indictment to the jury and made comments suggesting defendants often dispose of evidence. The defense asked the judge to instruct the jury that a defendant is presumed innocent and that an indictment is not evidence; the judge refused both requests and gave only a brief explanation of reasonable doubt.

Reasoning

The Court examined whether the Constitution’s guarantee of a fair trial under the Fourteenth Amendment required the requested instructions. It explained that an instruction stressing the presumption of innocence helps jurors avoid giving weight to arrest, indictment, or the defendant’s status instead of the trial evidence. Given the trial’s “skeletal” instructions, the prosecutor’s comments, and the risk that jurors might consider extraneous facts, the Court concluded refusal to give the presumption instruction denied the defendant a fair trial in these circumstances and therefore violated due process.

Real world impact

The judgment of conviction was reversed and the case sent back for further proceedings consistent with the opinion. Going forward, judges must give a requested presumption-of-innocence instruction when the surrounding trial context creates a real danger that jurors will rely on indictment, arrest, or other outside matters instead of the evidence presented.

Dissents or concurrances

One Justice concurred, urging routine granting of such requested instructions. A dissent argued that an instruction is not always constitutionally required if reasonable-doubt instructions and voir dire already protect the defendant.