The following excerpt is from U.S. v. Caldwell, 989 F.2d 1056 (9th Cir. 1993):
Failing to instruct jurors about an essential element of a crime is constitutional error because it lets them convict without finding the defendant guilty of that element. Cabana v. Bullock, 474 U.S. 376, 384, 106 S.Ct. 689, 696, 88 L.Ed.2d 704
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