C O M P A R AT I V E S T U D Y Miles v. United States (1881) Miles v. United States was the first case in which the US Supreme Court addressed the issue of the definition of the reasonable doubt standard. As one of the grounds of error, the petitioner referred to the jury instruction defining reasonable doubt:405 The prisoner’s guilt must be established beyond reasonable doubt. Proof beyond a reasonable doubt is such as will produce an abiding conviction in the mind to a moral certainty that the fact exists that is claimed to exist so that you feel certain that it exists. A balance of proof is not sufficient. A juror in a criminal case ought not to condemn unless the evidence excludes from his mind all reasonable doubt; unless he be so convinced by the evidence, no matter what the class of the evidence, of the defendant’s guilt, that a prudent man would feel safe to act upon that conviction in matters of the highest concern and importance to his own dearest personal interests.406 The US Supreme Court found no error in this instruction. The US Supreme Court relied on several state cases, including Webster and Giles, reasoning that: The evidence upon which a jury is justified in returning a verdict of guilty must be sufficient to produce a conviction of guilt, to the exclusion of all reasonable doubt. Attempts to explain the term “reasonable doubt” do not usually result in making it any clearer to the minds of the jury. The language used in this case, however, was certainly very favourable to the accused and is sustained by respectable authority.407 Portentously, the US Supreme Court observed that attempts to clarify the term “reasonable doubt” would likely result in confusion, rather than clarity. Although the US Supreme Court explicitly recognized the dangers of attempting to define the term “reasonable doubt,” it did not suggest any solution to the potential problem. Professor Miller W. Shealy Jr. notes in his analysis of Miles the failure of the Court at this early stage “to firmly settle on a definition marks the origin of the problem.”408 Miles v. United States, 103 U.S. 304, 312 (1881) (hereinafter “Miles”). Miles, at 309. 407 Miles, at 312, citing Webster; Arnold v. State, 23 Ind. 170 (1864); State v. Nash, 7 Iowa 347 (1858); State v. Ostrander, 18 Iowa 435 (1865); Donnelly v. State, 26 N.J.L. 601 (1857); Winter v. State, 20 Ala. 39 (1852); Giles. 408 Shealy, p. 233, supra n.21. 405 406 97