In 1994, the United States Supreme Court considered whether the jury instructions defining “reasonable doubt” in two state criminal cases violated due process. See Victor v. Nebraska, 511 U.S. 1, 6 (1994). This decision established that:
“The beyond a reasonable doubt standard is a requirement of due process, but the Constitution neither prohibits trial courts from defining reasonable doubt nor requires them to do so as a matter of course. Indeed, so long as the court instructs the jury on the necessity that the defendant’s guilt be proved beyond a reasonable doubt, the Constitution does not require that any particular form of words be used in advising the jury of the government’s burden of proof. Rather, ‘taken as a whole, the instructions [must] correctly conve[y] the concept of reasonable doubt to the jury.’ ”