jury instructions
CALCRIM Checklist CALJIC Comparison Matrix
CALCRIM Checklist/Worksheet
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Note: This list does not include fact and crime-specific instructions which must also be given.
Key:
S= sua sponte duty in every case
ss = sometimes sua sponte, depending on the facts
rec = not sua sponte, but recommended
R = must be given if requested
Pretrial General Instructions
□ 100 trial process
□S 101 cautionary admonition
□ 102 note taking
□S 103 reasonable doubt
□ 104 evidence
□S 105 witnesses
□R 106 juror questions
Pretrial Admonitions
□ss 120 service provider for disable juror (when one is used)
□rec 121 duty to abide by ct translation
□ss 122 corporation is a person (when defendant is a corporation)
□ss 123 witness identified as J. Doe (when victim is id’d as such)
□S 124 separation admonition
Post-Trial Introductory
□S 200 duties of judge and jury
□S 201 do not investigate
□rec 202 note taking
□ss 203 multiple defendants (when multiple D’s are on trial)
□ss/R 204 restrained defendant (if seen by jury)
□ 205 charge removed from jury consideration
□ 206 a defendant removed from the case
□ 207 proof need not show actual date
General Legal Concepts
□S 220 reasonable doubt
□ss 221 reasonable doubt/bifurcated trial (when bifurcated proceedings)
□ 222 evidence
□S 223 direct & circumstantial evidence: defined
□ss 224 circumstantial evidence: sufficiency of evidence (if DA substantially relies on it)
□ss 225 circumstantial evidence: intent/ mental state (if DA subst. relies as evid. of intent)
□S 226 witnesses
Causation
□ss 240 causation (when it’s at issue)
Union of Act and Intent
□ss 250 union act & intent: general intent (when charged with general intent crime)
□ss 251 union act & intent: specific intent (when charged with specific intent crime)
□ss 252 union act & intent: general & specific together (when charged with both types)
□rec 253 union act & intent: criminal negligence
□ 254 union act & intent: strict liability
General Evidentiary Instructions
□R 300 all available evidence
□S 301 single witness’s testimony
□S 302 evaluating conflicting evidence (unless corroborating evidence is req.)
□R 303 limited purpose of evidence
□R 304 multiple defendants: ltd. admissibility of evidence
□R 305 multiple defendants: ltd. admissibility D’s statements
□ 306 untimely disclosure of evidence
Witnesses
□R 315 eyewitness identification
□R 316 witness credibility, other conduct
□ 317 prior testimony unavailable witness
□ 318 prior statements as evidence
□ 319 prior statements of unavailable witness
□R 320 exercise of privilege by witness
□R 330 testimony of child 10 yrs or less
□R 331 testimony of witness with disabilities
□ss 332 expert witness testimony (when expert testimony received at trial)
□R 333 opinion testimony of lay witness
□ss 334 accomplice testimony corroborated: (if evid. suggests witness can be accomplice)
□ss 335 accomplice testimony: (when no dispute witness is an accomplice)
□R 336 in-custody informant
□ss 337 witness restrained (when seen by jury)
Character Evidence
□R 350 character of defendant
□R 351 cross-exam of character witness
Defendant’s Testimony
□R 355 defendant’s right not to testify
□R 356 Miranda-defective statements.
□ss 357 adoptive admissions (when such evidence is admitted)
□ss 358 evidence of defendant’s statements (for out-of-court oral statements by D)
□ss 359 corpus delicti (if 357 given & whenever stmts. form part of prosecution evid.)
□ 360 statements to experts
□ 361 failure to explain/deny adverse testimony
□ss 362 consciousness guilt: false stmt. (when such inference can be drawn from D’s stmt.)
Particular Types of Evidence
□ 370 motive
□ 371 consciousness guilt: suppress/fabricate evidence
□ss 372 flight (when DA relies on it to show consciousness of guilt)
□R 373 other perpetrator
□ss 374 dog tracking evidence (when they are used to prove id of defendant)
□R 375 1101(b) evidence
□ss 376 possession of recently stolen property (if there is evid. of such property
Aiding & Abetting & Related Doctrines
□ss 400 aiding & abetting: general principles (when DA relied on it as theory of liability)
□ss 401 aiding & abetting: intended crimes (when DA relied on it as theory of liability)
□ss 402 natural & probable consequences (target and non-target offense charged)
□ss 403 natural & probable consequences (only non-target offense charged)
□R 404 intoxication
Defenses and Insanity
□ 3400 alibi
□R 3428 mental impairment as defense
Concluding Instructions
□ss 3500 unanimity (if DA presents evid. of multiple acts to prove a single count)
□ 3501 unanimity: generic test. presented
□ss 3502 unanimity: election by prosecutor (if DA has picked a specific factual basis)
□R 3515 multiple counts: separate offenses
□ss 3516 multiple counts: alternative charges (if D alt. charged with mult. cts. for 1 event)
□ss 3517 LIO’s or degrees w/o Stone Instruction (where 1 or more LIO submitted to jury)
□ss 3518 LIO’s or degrees w/ Stone Instruction (where 1 or more LIO submitted to jury)
□ss 3530 judge’s comment on evidence (when the court comments)
□ss 3531 service provider for disabled juror (when one is used)
□S 3550 pre-deliberation instruction
□ss 3575 substituting alternate juror during deliberations (when alt. juror is seated)
□S 3590 final instruction on discharge of jury