2.17 Character Evidence

[Defendant] presented evidence to show that [he/she] enjoys a reputation for honesty, truthfulness and integrity in [his/her] community. Such evidence may indicate to you that it is improbable that a person of such character would commit the crime[s] charged, and, therefore, cause you to have a reasonable doubt as to [his/her] guilt. You should consider any evidence of [defendant]’s good character along with all the other evidence in the case and give it such weight as you believe it deserves. If, when considered with all the other evidence presented during this trial, the evidence of [defendant]’s good character creates a reasonable doubt in your mind as to [his/her] guilt, you should find [him/her] not guilty.


This instruction is based upon United States v. Winter, 663 F.2d 1120, 1146-49 (1st Cir. 1981), and United States v. Lachmann, 469 F.2d 1043, 1046 (1st Cir. 1972). The First Circuit explicitly rejects the instruction that good character evidence “standing alone” is sufficient to acquit. Winter, 663 F.3d at 1145.