The following excerpt is from U.S. v. Estrada, 988 F.2d 123 (9th Cir. 1993):
This court has not resolved whether a district court's denial of a proposed jury instruction is reviewed de novo or for an abuse of discretion. United States v. Streit, 962 F.2d 894, 897 (9th Cir.), cert. denied, 113 S.Ct. 431 (1992). It does not matter in this case, however, because under either standard the district court acted properly.
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