The following excerpt is from U.S. v. Ritchie, 948 F.2d 1293 (9th Cir. 1991):
We need not decide the standard of review for a district court's denial of a proposed jury instruction because the court's decision not to submit the defendants' instructions, even reviewed de novo, was correct. Compare United States v. Whitehead, 896 F.2d 432, 434 (9th Cir.), cert. denied, 111 S.Ct. 342 (1990) with United States v. Busby, 780 F.2d 804, 806 (9th Cir.1986).
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