Cage v. Louisiana
Annotate this Case
498 U.S. 39 (1990)
U.S. Supreme Court
Cage v. Louisiana, 498 U.S. 39 (1990)
Cage v. Louisiana
Decided Nov. 13, 1990
498 U.S. 39
The Due Process Clause of the Fourteenth Amendment
"protects the accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime with which he is charged."
In re Winship, 397 U. S. 358, 397 U. S. 364. Petitioner Cage was convicted in Louisiana of first-degree murder and was sentenced to death. In his trial's guilt phase, the jury was instructed that guilt must be found beyond a reasonable doubt, that reasonable doubt was "such doubt as would give rise to a grave uncertainty" and "an actual substantial doubt," and that what was required was a "moral certainty." In affirming Cage's conviction, the State Supreme Court rejected his argument that, inter alia, the instruction violated the Due Process Clause, and concluded that, "taking the charge as a whole," reasonable persons would understand the reasonable doubt definition.
Held: The instruction was contrary to the "beyond a reasonable doubt" requirement articulated in Winship. The words "substantial" and "grave" suggest a higher degree of doubt than is required for acquittal under the reasonable doubt standard. When those statements are then considered with the reference to "moral," rather than evidentiary, certainty, a reasonable juror, taking the charge as a whole, could have interpreted the instruction to allow a finding of guilt based on a degree of proof below that required by the Due Process Clause.
Certiorari granted; 554 So.2d 39, reversed and remanded.
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