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Judge H. Lee Sarokin

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The Reason for the Not Guilty Verdict in the Casey Anthony Case

Posted: 07/15/11 11:12 AM ET

The jury in the Casey Anthony trial was not instructed that circumstantial evidence is entitled to the same weight and consideration as direct evidence. Indeed, the words "circumstantial evidence" do not appear anywhere in the court's charge to the jury. I do not know whether or not the prosecution requested such an instruction, but the court did not give it, and apparently Florida law does not provide or require it.

The fact that Casey Anthony was the last person to have custody of her daughter, failed to report her missing (or dead) for 31 days, consistently lied once confronted, and the child was found dead and hidden, and she failed to tell what actually happened despite repeated opportunities to do so to her family, friends or law enforcement, (even when faced with the death penalty) was sufficient to find her guilty -- not necessarily of premeditated murder, but certainly all lesser charges. The duct tape and other forensic evidence provided additional, but not necessary, evidence.

Jury charges are invariably long and complex and difficult to understand. The courts have been struggling for years to make them shorter and simpler. Pattern and model charges are common in many jurisdictions. In the process some essential instructions may have been deleted. Traditionally, jury instructions contained language along the following lines (excerpts from a Connecticut model instruction):

There are, generally speaking, two kinds of evidence, direct and circumstantial. Direct evidence is testimony by a witness about what that witness personally saw or heard or did. Circumstantial evidence is indirect evidence, that is, evidence from which you could find that another fact exists, even though it has not been proved directly. There is no legal distinction between direct and circumstantial evidence as far as probative value; the law permits you to give equal weight to both, but it is for you to decide how much weight to give to any particular evidence.

Circumstantial evidence of an event is the testimony of witnesses as to the existence of certain facts or evidence or the happening of other events from which you may logically conclude that the event in question did happen. ***Assume that it is a December night, the weather is clear, there is no snow on the ground, and you retire for the evening. You wake up the next morning, you look out the window and you see snow on the ground and footprints across your lawn. The evidence that the night before there was no snow on the ground and the next morning there was snow on the ground and footprints across your lawn is direct evidence. That direct evidence, however, is circumstantial evidence of the fact that some time during the night it snowed and that some time thereafter someone walked across your lawn.

There is no reason to be prejudiced against evidence simply because it is circumstantial evidence. You make decisions on the basis of circumstantial evidence in the everyday affairs of life. There is no reason why decisions based on circumstantial evidence should not be made in the courtroom. In fact, proof by circumstantial evidence may be as conclusive as would be the testimony of witnesses speaking on the basis of their own observation. Circumstantial evidence, therefore, is offered to prove a certain fact from which you are asked to infer the existence of another fact or set of facts. Before you decide that a fact has been proved by circumstantial evidence, you must consider all of the evidence in light of reason, experience and common sense.

Obviously I cannot be certain that such an instruction would have made a difference. However, the few tidbits received from jurors seem to suggest that the lack of direct evidence of guilt was the prime factor in their verdict. Although many, if not most disagree with the verdict (myself included), neither the jury nor the court can be faulted. The jury followed the law as given, and the judge instructed the jury as required. Nor can I find any fault with the prosecution team, which in my opinion, performed with great competence and integrity. I cannot lavish such praise upon defense counsel, but I suppose their victory for their client moots any criticism of their tactics -- a subject possibly for another day.

In my more than 50 years in the law I personally experienced disagreement with a jury verdict twice -- once as a trial lawyer and once as a trial judge. Practically everyone reads or hears about verdicts with which they disagree. I know I do. But with minor, but sometimes very serious exceptions in both findings of guilt and acquittal, the system works well and the jury gets it right. Nothing could be worse than to harass or threaten jurors for their verdicts. Jury service is both a duty and a sacrifice; no one should be condemned for pursuing their conscience.

 
The jury in the Casey Anthony trial was not instructed that circumstantial evidence is entitled to the same weight and consideration as direct evidence. Indeed, the words "circumstantial evidence" do ...
The jury in the Casey Anthony trial was not instructed that circumstantial evidence is entitled to the same weight and consideration as direct evidence. Indeed, the words "circumstantial evidence" do ...
 
 
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10:40 AM on 07/29/2011
News reporter Calvin Drake Fell, has followed the Anthoy Sowell story since 1959 When the team of blacks came into he old carver projects to take the lives of many black and t heir children using the voice to skull method on them by communication their prerecorded conversation to their audio ear to control their thoughts, I, have written all the information down and made entries into my blog
for the entire population of the City of Cleveland could have the first hand knowledge of hoe the voice to skull system was used on them and their children inducing on them criminal behavior, against their free mind and free will.

http://jjdpcalvindrakeministries.blogspot.com

The team of blacks created a organized crime team to murder

Written by Calvin Drake Fell
11:15 AM on 07/21/2011
The jury spoke and that should be the end of it. I would bet my almost anything that you couldn't get 12 random people to completely agree on almost anything. The fact that they were able to do so here ought to be enough. #thejusticesystemworks
11:13 AM on 07/21/2011
It is, above all else, most disheartening to see former members of the judiciary and former lawyers take part in such hogwash and continue to sully the image of my chosen profession. These people, the media, and you weren't in the courtroom and nor did you did hear all of the evidence, or possibly you even heard too much of it. The juror's did their job, they heard what evidence was allowed to be admitted, disregarded that "evidence" which they might have heard else where, and gave their verdict. People need to remember that it's the State's job to prove that the defendant is guilty, not the defendant's job to prove their own innocence. The knowledge that every once in a while a guilty person may go free, and the willingness to let that happen in order to ensure that an innocent person isnt jailed without the property amount of evidence to put them there is at the very heart of the 5th Amendment -- no person can be deprived of life, liberty, or property without the due process of the law.
11:23 PM on 07/21/2011
But innocent people would not be convicted so often if they had access to the kinds of defense lawyers Casey Anthony and OJ had. By marshalling an unusual arsenal of questionable witnesses and red herrings, the defense was able to confuse the jury, who fell prey to a lot of nonsensical posturing and theatrics.
Not to mention "social media" research by trial consultants.
Your point would be well taken if the playing field were level. But we know it's not. Truly indigent defendants (not those who sell photos to TV networks for hundreds of thousands of dollars) are seriously disadvantaged. That's the true injustice.
08:07 AM on 07/22/2011
The fact that the media can make untold millions by selling case and then turn around and lambast the person whose life they're profiting off of for making a buck off of the infamy they themselves have spun up is ludicrous. She has just as much a right to get her story out as they do.

You've bought in, sir. And you're just looking for an excuse to moan and groan... get over it and move on. #yourlife'stooimportant.
11:13 AM on 07/21/2011
Evidently I'm the only one who doesn't actively participate in the court of public opinion. Justice served is justice done. The state failed to meet its burden and any person against whom the state can't provide such evidence as to put all of a reasonable doubt beyond 12 juror's minds shouldn't be convicted -- especially of murder. If you'd like to live in a world where that can happen, go back to 1775, or most of the rest of the world today for that matter.

The reaction to The State v. Anthony verdict just proves, once again, that the media has brainwashed you by the millions. For months you were spoon-fed tidbits of information that condemned Casey Anthony- the same tidbits that would undoubtedly increase ratings. And now, in the face of a finding of "not guilty," every person entranced by those same tidbits is in utter shock. -- I'm shocked too... Shocked that more of you do not understand the prosecution's need to prove guilt beyond a reasonable doubt, and shocked that one's peculiar penchant for elaborate tall tales and inopportune tramp stamps should be enough, for some of you (here's to you Nancy Grace), to meet this standard. Whatever happened to poor Caylee is surely an unspeakable tragedy, but let us not forget that supposed guilt according to oft-misguided public opinion means nothing in a court of law."
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IamYourDrillThrall
You can't be pro-war & pro-life.
08:52 AM on 07/20/2011
Good article, but with one inaccuracy. Casey did not "wait 31 days to report her child missing." She NEVER reported Caylee missing. Cindy, her mother, called 911 to report it, and then MADE Casey talk to the dispatcher. LIsten to the call; it is bone-chilling. Cindy acts normally...hysterical, and frantic, as any mother or grandmother would be. Casey is calm and matter-of-fact. She pretty much acts as if she doesn't care at all where her daughter is. Not a trace of emotion or desparation. She's a freak, and I think the jury got it WRONG. A killer walked free. And we are diminished.
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Judge H. Lee Sarokin
Retired after serving 17 years on the federal cour
12:29 PM on 07/20/2011
IamYourDrillThrall - You are absolutely correct. I did attempt to clarify that in reply below in setting forth the questions the jury would or should have considered:
"Why would a mother not report her child missing (or dead) and would have continued if not confronted by her own mother?" - but thanks for the clarification--it is important.
11:19 PM on 07/28/2011
I thought the same thing every time I heard that call to. She never ever reported she was forced by her mother. And, then even after in jail knowing everyone knew Caylee was missing and she called home without care about how everyone else felt. She just wanted for herself she wanted her boyfriends number. I mean her family meant nothing to her and Caylee she proved at every turn did matter. On the camara while her parents visits she states. I am here in jail and all anybody cares about is Caylee. And, then when told the media saying she drown. Suprise!! Suprise!! But, then we used that as her defence. Come all there is no doubt if you put all the pieces together what happened. All had to do with Casey needing life to be about Casey not Caylee.
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maybesomeday
If you take short cuts your always gonna come up s
08:41 AM on 07/20/2011
Great article written here. For a change we lay people who have no idea what the terminology of law is made is understandable to me. I personally think that the prosecution put on a great case, full of great evidence, so it is nothing short of shocking that she wasn't found guilty. Maybe it's time for those in the know of what it all means when it comes to jury instructions, to sit up and take notice that this particular jury didn't understand the instructions given, and didn't bother to ask the question of Judge Perry. They lacked the passion necessary for deliberations and probably had their minds made up right after opening statements. Their lack of interest in getting to the proper verdict laid out in front of them showed by their own actions. Going on their own memories rather than taking notes for a 6 week trial spoke volumes.
With 30 pages of jury instructions I would have thought that in and of itself would take them 11 hours. And then it seems they tossed those instructions in the garbage and came up with their own verision of what they thought.
Given that this article clarifies what circumstantial evidence actually is, this jury obviously didn't know going into deliberations that this evidence was to be given the same weight as any witness account. I don't blame them, I blame those instructions for not bringing it down a few notches where regular people could understand it.
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guitargeorge1964
Independent!!!
11:50 PM on 07/19/2011
Very interesting as always Judge.

I had a curious incident with a coworker about this trial. The woman in the office next to mine had the feed from the trial streaming on her computer for the entire duration. I don't normally pay attention to such things but several days before the verdict I asked her if they were going to convict Casey Anthony. I was very surprised when she said "No". Her reason was that, although she thought Anthony was guilty, the prosecutor hadn't proved it to her. I was surprised because I just followed the trial very casually what was in the newspaper or the radio, and assumed she would be found guilty based on what I heard, but here was a person watching very closely who said the opposite. So, when the verdict came out, I really wasn't too surprised, yet still confused on how they got there.
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Judge H. Lee Sarokin
Retired after serving 17 years on the federal cour
12:47 AM on 07/20/2011
guitargeorge1964 - Thanks. Your comment raises the repeated question as to whether or not televised trials are a good or bad thing. I was in favor of televising the O.J. Simpson trial because I believed that when he was convicted those who watched would not attribute the verdict to racism, because they would have had the opportunity to view the evidence against him first hand. You see how well that worked out. Here, I think that most people who watched this entire trial (or most of it) were shocked by the verdict after seeing all of the evidence. So for me, the jury is still out on whether televising jury trials is a good or bad thing. I would be very upset if people watching would conclude that the system was not working well, because, despite its flaws and occasional miscarriages, I believe in it.
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guitargeorge1964
Independent!!!
08:45 AM on 07/20/2011
Judge,
Speaking of the system. I see the civil lawsuits already being filed against the Anthonys. I can already see a comparison to OJ Simpson in which he was found not guilty in his criminal trial, yet people were able to use the system to punish him harshly anyway.

Although I know OJ was guilty of the last crime in which he was convicted, it bothers me to no end that the guy who first told him about his stolen memorabilia, encouraged him to go and get it back, secretly taped the whole incident (and sold the recording to the media), was given immunity and testified against him. When you look at the sentencing it does not appear justice was blind or impartial. It appears that he was given a long sentence because of his notoriety.
In that case it appears that the system was abused to accomplish a specific task, to get OJ.
I'm very curious to hear your thoughts on that. I hope you respond. Thanks
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IamYourDrillThrall
You can't be pro-war & pro-life.
08:53 AM on 07/20/2011
The last thing our society needs is more secrets. I support cameras in the courtroom. We need as many eyes as possible watching.
04:04 PM on 07/19/2011
Thanks, Judge Sarokin, for this post. It's clear from many discussions I've read or heard over the last weeks that many people believe that circumstantial evidence can not in itself constitute proof; they believe their must be evidence that is not only direct, but physical, to prove guilt.
Clarification from the legal community is helpful.
03:59 PM on 07/19/2011
Even though I tend to be more conservative than most of the folks that read the Huffington Post, I have no regard for our "criminal justice system". I believe that it's a three way oxymoron. It's neither a system (that works) nor does it bring justice to criminals. I have yet to meet more than a handful of police offices that are honest and prosecutors are gulible enough to believe them. I do have absolute faith in the Jury System and it was briliant of our fore fathers to institute that.

That said, I think that this was a case of the police looking for evidence that fit their theory. In real science, you follow the evidence where it takes you. The State's Attourney was out-lawyered by Ms. Anthony's lawer and she was aquitted. Whether the jurors got good advice or not really doesn't matter all that much, their instructions were in accordance with Florida law.

When I see something like this, I ask, "Which is better, for a guilty person to go free or for an innocent person to get the death penalty?" It's cases like this that make me more and more opposed to the death penalty.
02:41 PM on 07/19/2011
Im wondering, if maybe, just MAYBE, these obviously VERY misguided jurors werent so misguided afterall. Im entertaining the thought that they may have deliberately voted not guilty, thus insuring that Casey will be harassed and harangued for the rest of her life, with the great possibility of being killed after she is located-surely a fate worse than prison. If this is the correct assumption-BRAVO, however, in either case, you, the jurors were wrong.....
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IamYourDrillThrall
You can't be pro-war & pro-life.
08:55 AM on 07/20/2011
Interesting theory. I had similar thoughts, but for a different reason. By voting "Not Guity", which, lets face it, NO ONE expected, those jurors became infamous. I read somewhere that one juror quit her job and hired a publicist. They will make thousands of dollars from interviews and articles.

Wonder if anyone discussed THAT behind closed doors, hmmm?
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JeffShaffer
10:54 AM on 07/19/2011
The reason for not guilty is simple. First they removed Mother Wit. Then, they followed instructions. Our country is filled with people who do whatever THEY say. The ability to reason is gone and when the older generation is gone so will the ability for anyone to think for themselves. It is what it is, is the new way of living in our country. And, if you want to feel the heat all you have to do is say that you are mad as Hell and you will not take it anymore.
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ThomasMc
Christian morality is an oxymoron.
10:53 AM on 07/19/2011
The reason the jury let her go is because they watch too many crime/legal dramas on tv, where the prosecution is able to provide the tiniest detail into how the crime was committed. Because real life didn't compare to their fictional experience, they let her go. They should have done their duty, and voted on whether or not she was guilty, not whether or not on whether it would make a good episode on CSI:Miami.
06:05 PM on 07/19/2011
Yea Tom, no doubt thats the reason.( I hope you know Im being sarcastic) Yet I send my message with no malice because I am also a member of the lowest form of life on this planet.....Good Luck to us!!
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Moonspirit48
Happy to be alive ...
10:35 PM on 07/18/2011
What I don't understand is why this case cannot be appealed? It seems to me that the judge was in error by not telling the jury that circumstantial evidence held equal weight to direct evidence. Since the jurors have said that they were sickened by having to give a Not Guilty verdict due to lack of direct evidence, it seems likely that their verdict would have been different had they known that they could give equal weight to circumstantial. Further, I've read that there was quite a lot of circumstantial evidence that was not presented to the jury. This seems very wrong, if it is true.
11:25 PM on 07/18/2011
Appeals are for criminal defendants who have been convicted. The rules of double jeopardy prevent the state from ever trying a defendant twice for the same crime after a finding of Not Guilty, even if errors have been committed in the first trial. Yes, it sounds unfair, but that's the grand bargain we struck with the Constitution.

It's heavily biased towards the defense for a reason: at some point as a society we made the collective decision that it is better to let a thousand guilty people walk than to imprison one innocent person. Many countries do not have trial by jury, the presumption of innocence, double jeopardy, or the right against self incrimination. Casey Anthony is benefiting, to be sure, but so are the rest of us.
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Moonspirit48
Happy to be alive ...
11:50 PM on 07/18/2011
Thanks much for the information. :-) F&F
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03:25 AM on 07/19/2011
You are incorrect. Appeals are for either party.
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Judge H. Lee Sarokin
Retired after serving 17 years on the federal cour
01:52 AM on 07/19/2011
Moonspirit48 - kwyang has said it well. Under our Constitution appeals by the prosecution from acquittals are not permitted. I also want to mention that the failure of the judge to charge the jury regarding circumstantial evidence apparently was not an error under current Florida law. I researched Florida law before writing the article and apparently that instruction is no longer required. The judge followed the Florida model jury charge in every respect.
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Moonspirit48
Happy to be alive ...
01:17 PM on 07/19/2011
Thank you, Judge Sarokin. I faved you but had already fanned you :-)
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Sanity Inspector
He who laughs, lasts.
09:19 PM on 07/18/2011
If it were being tried under Scottish law, maybe they would have returned a verdict of Not Proven.
MHT73
words matter
08:25 PM on 07/18/2011
An excellent post, your honor, and I think you've identified the critical, missing element in this case.

I saw some members of the OJ jury interviewed a few years ago, and was struck by how they understood the standard of 'beyond a reasonable doubt' to be closer to 'beyond any crazy theory that someone could cook up and make into a movie.' They didn't quite go so far as to say that OJ had to be found not guilty because space aliens might have done it, but their reasoning was close to that.

An additional contributing factor is that everyone who watches crime shows on television "knows" that forensic evidence can prove things 100 percent. Rarely so, but expectations are high.