John Edwards And Proof Beyond A Reasonable Doubt

After three weeks of trial and nine days of deliberation, the jury found John Edwards Not Guilty on one charge and could not reach a unanimous verdict on the other five charges involving campaign finance fraud. Similar to the O.J. Simpson trial, the verdict and the jurors have been the subject of controversy and criticism. What the critics should grasp, and don’t seem to, is this: “not guilty” means “not proven”; it doesn’t mean “innocent”.

A cornerstone of our legal system is the idea that “it is better that ten guilty persons escape than that one innocent suffer” (known as “Blackstone’s formulation“). The due process clauses of the Fifth and Fourteenth Amendments to the United States Constitution say no person shall “be deprived of life, liberty, or property, without due process of law”. Due process of law, in criminal cases, means the government must prove allegations beyond a reasonable doubt. As Justice Brennan said in In Re Winship:

The requirement of proof beyond a reasonable doubt has this vital role in our criminal procedure for cogent reasons. The accused, during a criminal prosecution, has at stake interests of immense importance, both because of the possibility that he may lose his liberty upon conviction and because of the certainty that he would be stigmatized by the conviction. Accordingly, a society that values the good name and freedom of every individual should not condemn a man for commission of a crime when there is reasonable doubt about his guilt.

The requirement of proof beyond a reasonable doubt applies to D.U.I./O.V.I. cases. If a person is facing significant consequences and stigma upon conviction for an O.V.I., then the government must prove to the jurors beyond a reasonable doubt the person operated a vehicle under the influence. An arresting officer may charge a defendant with O.V.I. based on observations and evidence like field sobriety tests and chemical tests. To charge the defendant with O.V.I., the arresting officer only needs “probable cause” to believe the defendant was under the influence. It is then up to the jury to decide whether the evidence proves beyond a reasonable doubt the defendant was under the influence. If there is doubt, and the doubt is reasonable, then the verdict should be Not Guilty.
In the Edwards case, the jurors had doubt about whether Edwards committed the alleged crimes. Although their comments indicate they think he was guilty, the evidence did not convince them he committed a crime. While the jurors have been criticized for not finding Edwards guilty, the critics did not hear all of the evidence, and the jurors did. They did not find him “innocent” (as there is no “innocent” verdict), they found him “not guilty”, and “not guilty” simply means “not proven”.

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