California, United States of America
The following excerpt is from People v. Ajtun, B291125 (Cal. App. 2020):
10. Ajtun is correct the court in People v. Reliford, supra, 29 Cal.4th at page 1013 did not confront the precise argument asserted by Ajtun that the trial court's instruction with CALCRIM No. 220that the standard of proof beyond a reasonable doubt applies unless the court instructs the jury "otherwise"because CALJIC No. 2.90 did not contain similar language. However, the reasoning in Reliford approving the uncharged crimes instruction as properly stating the burdens of proof for charged and uncharged crimes evidence is directly on point.
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