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On Demand Audio

Federal Jury Instructions

(843 reviews)

Produced on December 06, 2016

Taught by
$ 59 Criminal, Litigation, and Public Interest In Stock

Course Information

Time 61 minutes
Difficulty Advanced

Course Description

When a lawyer stands up to address a jury, the old adage often applies: it’s not what you say, but how you say it. The last words in every criminal trial, however, are uttered in a monotone voice by a judge who gives a lengthy, complex and often convoluted dissertation on the law the jurors must apply in deciding the case. Since lawyers have no control over how those words are spoken, it is critically important to make objections to and requests for, not only particular concepts, words, and phrases, but also the order in which they are related to the jury and the frequency with which they are repeated. A discussion of when the jury should acquit, for example, should precede the instruction on when to convict, because acquittal should always be the first option. The words reasonable doubt cannot be repeated often enough.

Especially in the area of white collar crime, the law is continually shifting. It is incumbent on the defense lawyer to be aware of those changes and to be prepared to incorporate language from new cases into pattern jury instructions.

This program focuses on fine-tuning the lawyer’s ear to the words, phrases and characterizations that prejudice the defendant and favor the prosecution. It also addresses and encourages lawyers to make more objections and to propose alternative language that is at least balanced, if not more advantageous to their clients. This program is taught by Susan Wolfe, who has been practicing criminal defense for over thirty years in the trial and appellate courts and has rarely met a jury instruction she could not improve upon. She has even requested that a judge deliver the presumption of innocence instruction with greater emphasis, enthusiasm and intensity.   

Learning Objectives:
  1. Listen for words, phrases and the ordering of concepts that should be revised for clarity and balance, and convince the judge that the pattern jury instructions are wrong, insufficient and unfair
  2. Understand how to submit and preserve objections and propose alternative language, in order to persuade a judge to re-evaluate “the way it’s always been done”
  3. Analyze selected pattern jury instructions to be able to argue that they do not apply to the facts of the case on trial
  4. Review important changes in the criminal laws and learn how to translate those changes into favorable instructions to the jury


Susan Wolfe

Law Office of Susan C. Wolfe

Susan Wolfe focuses her practice on white-collar criminal defense at both the trial and appellate levels. She is well-versed in federal securities laws, professional misconduct laws, the federal anti-spam act, and various anti-fraud laws, including mortgage and insurance fraud. She has represented professionals in the real estate, mortgage, securities, and healthcare industries and in the legal profession during all stages of the criminal process, including investigations, bail proceedings, plea negotiations, motions, trial, sentencing, direct appeals, cert petitions, habeas petitions, and collateral licensing matters.

An experienced appellate lawyer, Ms. Wolfe has written and argued numerous appeals. In the last year alone, after filing her clients’ briefs in the Second Circuit, she exacted from the government concessions of error requiring remand for resentencing.

Ms. Wolfe enjoys a robust private practice in Midtown Manhattan. She has taught trial skills for the Intensive Trial Advocacy Program at Cardozo School of Law, written practice commentaries for the National Institute of Trial Advocacy, and authored an article for the New York Law Journal celebrating the joys of brief writing (“How I Learned to Stop Worrying and Love the Brief”). She has been a member of several Criminal Bar Associations and a former member of the New York City Bar Association’s Committee on Legal Issues Pertaining to Animals.


Scott A.

excellent program

Matthew B.

Not my area, but a great and informative presentation!

Jake R.

I wasn't sure at first if I would like this course, but the presenter grew on me. The focus on federal criminal jury instructions provides a really good overview of some basic criminal law topics like conspiracy. Good course.

Brian P.

Presenter did a really great job.

Edward P.

This was a very thoughtful presentation.

Matt M.

quite helpful

Katherine P.

presenter Ms Wolf did a fine job!

Melody S.

I throughly enjoyed this lecture! Thank you.

Charles R.

Actually learned some things I did not know, and I know this area.

Frank O.

This gal knocked it outta the park!! She covered the law, but applied it to real life trial situations as well. Easily the most entertaining and best program so far!!!

Darrell R. J.

Really impressive presentation and very helpful. Please bring her back to discuss this topic in more detail.

Danielle W.

Extremely informative - learned a lot about an area of law I don't touch a bunch.

Julie A. B.

Great course with engaging instructor.

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