Whether the Due Process Clause requires trial courts to provide a definition of 'reasonable doubt' to a jury upon request in criminal proceedings

in Applicant’s case and due to counsel’s competing work obligations. 3. Applicant was charged in 2018 with various racketeering offenses related to his alleged involvement with a gang.! United States v. Sandoval-Rodriguez, No. 22-4330 (4th Cir.), Doc. 65 at JA 1845. While each of his co-defendants pleaded guilty, Applicant pleaded not guilty to all counts. United States v. Sandoval-Rodriguez, No. 22-4330 (4th Cir.), Doc. 62 at JA 5. The case proceeded to trial. United States v. Sandoval-Rodriguez, No. 22-4330 (4th 1 Applicant was also charged in a separate indictment in the District of Maryland for offenses similar to those in the present case, involving comparable conduct. He was tried and convicted alongside other co-defendants. Verdict, United States v. Sandoval-Rodriguez, No. (D. Md. Jan. 1, 2022), ECF No. 1384. Following the conviction, Applicant appealed on various procedural grounds, but the Fourth Circuit denied the appeal on April 9, 2025. United States v. Parada, 134 F.4th 188 (4th Cir. 2025). Applicant has moved for an extension of time to file a petition for certiorari from that judgment as well. That extension request is pending. Cir.), Doc. 62 at JA 13. The trial began on October 7, 2019 and lasted until November 1, 2019. Id. atJA 13-16 4. At the conclusion of trial, Applicant asked the district court to define the term “reasonable doubt” for the jury. United States v. Sandoval-Rodriguez, No. 22-4330 (4th Cir.), Doc. 64 at JA 1355-56. The district court denied that request. However, in doing so, the court noted that the “circuit has expressed a clear disapproval, if not an outright prohibition, of reasonable doubt instructions. I don’t agree with it. But I feel compelled to adhere to that disapproval.” United States v. Sandoval-Rodriguez, No. 22-4330 (4th Cir.), Doc. 64 at JA 1334-35 5. Applicant appealed. The Fourth Circuit affirmed the district court’s denial of the request for a jury instruction defining reasonable doubt, noting the “long standing” rule in the Fourth Circuit that, “although the district court may define reasonable doubt to a jury ** * the district court is not required to do so.” App. 13a (citation omitted). 6. This Court’s review is urgently needed to address a clear and acknowledged conflict among the federal courts of appeals and the state courts of last resort regarding whether a trial court in criminal proceedings must, upon request from the jury or the defendant, issue an instruction regarding the meaning of the “beyond a reasonable doubt” standard. Some courts take the position that a trial court may instruct jurors on the meaning of the “beyond a reasonable doubt” standard. See, e.g., United States v. Olivo, 328 F. App’x 668, 669 (1st Cir. 2009); Gaines v. Kelly, 202 F.3d 598, 605 (2d Cir. 2000); United States v. Shin, 560 F. App’x 137, 140 (3d Cir. 2014); Turner v. Johnson, 106 F.3d 1178, 1189 (5th Cir. 1997); United States v. Ashrafkhan, 964 F.3d 574, 578 (6th Cir. 2020); Harris v. Bowersox, 184 F.3d 744, 751 (8th Cir. 1999); Maybery v. Patton, 579 F. App’x 640, 644 (10th Cir. 2014); Icenhour v. Medlin, 567 F. App’x 733, 737 (11th Cir. 2014). Other courts suggest that a trial court should offer that instruction when the jury requests a definition. See, eg., United States v. Nolasco, 926 F.2d 869, 872 (9th Cir.) (en banc), cert. denied, 502 U.S. 833 (1991); United States v. Taylor, 997 F.2d 1551, 1558 (D.C. Cir. 1993). By contrast, still other courts, including the Fourth Circuit below, have held that trial courts should not provide the jury with an explanation of the reasonable-doubt standard even when the jury or the defendant requests it. See, e.g., United States v. Smith, No. 21-4328, 2023 WL 1433639, at *1 (4th Cir. Feb. 1, 2023), cert. denied, 143 S. Ct. 2597 (2023); United States v. Alt, 58 F.4th 910, 919 (7th Cir.), cert. denied, 143 S. Ct. 1097 (2023). 7. Although the Supreme Court observed in Victor v. Nebraska that “[t]he Constitution neither prohibits trial courts from