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In light of the recent decision by the U.S. Supreme Court in Smith v. United States, 133 S. Ct. 714 (2013), the 7th Circuit Court of Appeals’ Pattern Jury Instruction Committee has revised the withdrawal instructions.
Those instructions are 5.13, 5.14(A) and 5.14(B), and can be found on the court’s website.
The Supreme Court held that a defendant bears the burden of proving withdrawal from a conspiracy, which abrogates a line of 7th Circuit cases.
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