JURY INSTRUCTIONS
Special Instructions
12. Character Evidence
Revised CALJIC 2.40 & 2.41 (Character Trait for Sobriety)
Evidence has been received of the defendant’s character trait of moderate
use of alcohol. Such a character trait for moderate use of alcohol is consistent
with sobriety.
The character trait for moderate use of alcohol may be sufficient by itself
to raise a reasonable doubt as to the guilt of a defendant. It may be reasoned
that a person who drinks moderately may not be likely to commit the crimes of
driving under the influence.


