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WPIC 4.64.01 Evidence Limited as to Purpose

11 WAPRAC WPIC 4.64.01Washington Practice Series TMWashington Pattern Jury Instructions--Criminal

11 Wash. Prac., Pattern Jury Instr. Crim. WPIC 4.64.01 (5th Ed)
Washington Practice Series TM
Washington Pattern Jury Instructions--Criminal
December 2021 Update
Washington State Supreme Court Committee on Jury Instructions
Part I. General Instructions
WPIC CHAPTER 4.60. Miscellaneous Instructions During Trial
WPIC 4.64.01 Evidence Limited as to Purpose
I am allowing this evidence, but you may consider [the evidence] [the answer(s)] only for the purpose of . You may not consider [the evidence] [the answer(s)] for any other purpose.
This instruction is a generalized version of WPIC 4.64 (Evidence of Prior Conviction—Impeachment), to be used during trial when evidence is admissible only for a limited purpose other than impeachment by prior conviction.
Use bracketed material as applicable.
If the evidence consists of a criminal conviction offered for impeachment, use the more specific instruction in WPIC 4.64 (Evidence of Prior Conviction—Impeachment) rather than this general instruction.
For a corresponding written instruction to be used at the conclusion of the trial, see WPIC 5.30 (Evidence Limited as to Purpose).
Under the Evidence Rules, evidence may be admissible as proof on one issue but inadmissible as proof on other issues. On request by counsel for either side, a party is entitled to an instruction such as WPIC 4.64.01, limiting the evidence to its proper purpose. See Tegland, 5 Washington Practice: Evidence Law and Practice §§ 105.1–.4 (6th ed.).
In some situations, it may be necessary to supplement the language of WPIC 4.64 (Evidence of Prior Conviction—Impeachment) to satisfy specialized requirements in the case law, particularly with regard to evidence of prior conduct admitted under ER 404(b) and evidence of out-of-court statements by co-defendants. These specialized requirements are discussed in more detail in the Comment to WPIC 5.30 (Evidence Limited as to Purpose).
[Current as of May 2019.]
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