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Published on 9/23/2025, 12:00:00 PM

Maryland Jury Instructions and Their Role in Criminal Cases

Maryland juries do not guess at the law. Judges read the Maryland Criminal Pattern Jury Instructions, which explain legal standards like the presumption of innocence, reasonable doubt, how to weigh witness credibility, and how to consider scientific tests. The exact wording matters. A single instruction can shift how a jury views the State's evidence and can decide a case.

Use this guide to understand what instructions are, when they are given, and how a trial lawyer uses them to win.

What are Maryland Criminal Pattern Jury Instructions

They are model directions that judges use to tell jurors how to decide a case under Maryland law. They cover general duties of jurors, evidentiary rules, and the elements of specific crimes. Although a judge can tailor language to the facts, the pattern set is the starting point in almost every jury trial.

The core instructions every jury hears

  • Presumption of innocence and reasonable doubt. Jurors are told that the State must prove every element beyond a reasonable doubt and that the defendant is presumed innocent unless the State meets that burden.
  • Unanimity, deliberations, and impartiality. Jurors must decide the case only on evidence admitted in court, must deliberate together, and must reach a unanimous verdict if they reach any verdict at all.
  • Separate consideration of counts and defendants. In cases with multiple charges or co-defendants, jurors must consider each charge and each person separately to avoid spillover.

These directions frame how jurors view every witness, exhibit, and argument. Learn how forum choice interacts with instructions in our guide to bench vs. jury trials.

Elements instructions for specific charges

For each offense, the judge reads a short list of elements that the State must prove. That list controls the verdict. Examples:

A defense that knocks out one required element should result in an acquittal. That is why we build cross examinations and exhibits around the exact element language that the jury will hear.

Evidentiary instructions that shape credibility

Jurors get help evaluating proof. Common examples include:

  • Credibility of witnesses. Jurors may consider motive, bias, prior inconsistent statements, and how a witness behaved while testifying.
  • Accomplice or cooperating witness testimony. Jurors are cautioned to examine such testimony with care.
  • Expert testimony and scientific tests. Jurors learn how to weigh opinions and test results, including limits on what those tests actually prove. This is key in cases with breath or blood testing, field sobriety evidence, phone extractions, and lab work.

We align our motions and trial themes with these instructions so jurors have a legal reason to doubt weak or unreliable proof. For more on the law that sits behind many instructions, see our Maryland Criminal Laws hub and the broader Maryland Criminal Defense Overview.

When instructions are requested, argued, and decided

  • Before trial. Defense and the State file written requests for particular instructions and when no pattern exists, identifies problem areas where the State's proposed language is incomplete or unfair.
  • During trial. New issues can arise, for example when a witness gives unexpected testimony. Counsel may request a curative or limiting instruction right away.
  • End of trial. The judge settles final instructions on the record. Objections must be preserved, which protects appellate rights if the court refuses a correct instruction.

Clear, timely requests and objections matter. They preserve errors for review and often lead the court to give a fairer charge in the first place.

How instructions influence juror decision making

Jurors bring common sense to the courtroom, yet they must apply legal standards, not hunches. Instructions:

  • Focus the jury on the State's burden, not the defendant's.
  • Limit improper uses of evidence, for example prior bad acts admitted for a narrow purpose.
  • Reinforce that sympathy or prejudice has no place in deliberations.
  • Provide a lawful path to a not guilty verdict when an element is missing or when proof is uncertain.

We quote and paraphrase instruction language in openings and closings so jurors hear a single, consistent standard from start to finish.

Practical tips if your case may go to a jury

  • Ask your lawyer which specific instructions will apply in your case, including any lesser-included offenses.
  • Review the element list for your charges so you know what the State must prove.
  • Discuss credibility and scientific-evidence instructions, since those often drive reasonable doubt.
  • Understand the timing of requests and objections, which can affect trial strategy and any appeal.

If you are weighing a court election, read our bench vs. jury guide, then talk through the pros and cons for your facts and your venue.

Related resources

FAQs

Are pattern instructions mandatory in Maryland

Judges commonly rely on the pattern set because it is vetted and balanced, yet a court can tailor language to fit the evidence and the charges. Lawyers may request clarifications or additions, and they should object if the final wording is wrong.

Can the wrong instruction lead to a new trial

A material error on a key instruction can support reversal on appeal, which is why preserving objections is so important.

Do instructions change the State's burden

No. They explain it. The State always has to prove every element beyond a reasonable doubt, and jurors are told to acquit if they are not firmly convinced.

Need a trial plan that uses the instructions to your advantage. Talk with FrizWoods about your case, your forum options, and the exact instructions a jury would hear. Contact us for a free consultation.