OUJI-CR 13-26

CIRCUMSTANTIAL EVIDENCE -

EXCLUDING REASONABLE THEORIES OF INNOCENCE

The State relies [in part] in its case upon circumstantial evidence. In order to warrant a verdict that [Name of Child] is a delinquent child upon circumstantial evidence, each fact necessary to prove every element of the alleged offense must be established by the evidence beyond a reasonable doubt. All the facts necessary to such proof must be consistent with each other and with the conclusion the State seeks to establish that [Name of Child] committed the alleged offense. All of the facts and circumstances, taken together, must be inconsistent with any reasonable theory or conclusion that [Name of Child] did not commit the alleged offense. All of the facts and circumstances, taken together, must establish to your satisfaction beyond a reasonable doubt that [Name of Child] committed the alleged offense.