IN THE CIRCUIT COURT OF THE STATE OF OREGON
FOR MULTNOMAH OUNTY

THE STATE OF OREGON, 1 Case NO. 17CR34550

Plaintiff. 
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2 JURY INSTRUCTIONS -
SENTENCE ENHANCEMENT
JEREMY JOSEPH CHRISTIAN. 
Defendant. 

FUNCTIONS OF THE SENTENCING JURY

Now is the time for you to deliberate and to answer additional questions about this case.

\Vhen you return to the jury room. you must consider these questions as they relate to each of
the felony counts on which you rendered a guilty verdict. You will be presented a series of
questions and will answer the question "no" or "yes." The misdemeanor charges are not part 01?
your consideration.

A verdict of ?yes? on any particular fact means that the state has proved that fact beyond a
reasonable doubt. A verdict of?no" means the state has not proved that fact beyond a reasonable
doubt

As with the question of innocence or guilt, the defendant. Jeremy Christian. bears no burden

of proof on these questions. They are deemed not to exist as facts unless and until the state proves

them beyond a reasonable doubt. Therefore, the burden is on the State and the state alone to prove
these facts beyond a reasonable doubt.

Reasonable doubt is Reasonable doubt is doubt based on common sense and reason.
Reasonable doubt is not an imaginary doubt. Reasonable doubt means an honest uncertainty as to
the answer on these questions. You must answer the question "no" if, after careful and impartial
consideration of all the evidence in the case. you are not convinced beyond a reasonable doubt
that the answer to the question is "yes."

For Count 1 and Count 2. all 12 jurors must be in agreement before you can answer the
question ?yes.? At least 10 jurors must be in agreement before you can answer the question 
With respect to the remaining counts. at least 10 jurors must be in agreement before you can answer
the question ?no? or "yes." For any of the questions that are not a unanimous vote, please note in
the Spaces on the verdict fonn the number ofjurors voting no and the number ot?jurors voting yes.

In addition to any evidence you heard during this enhancement stage of the trial. you are
also allowed to consider all of the evidence you received during trial in this case.

The state has alleged the following additional facts that you are asked to consider:

1. The probability is high that the defendant cannot be rehabilitated
2. The Defendant?s crimes were precipitated by his unreasonable racial and religious bias
3. The Defendant demonstrated no remorse for his acts.

4. The Defendant's acts demonstrated his callous disregard for the value of human life.

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. The Defendant is likely to commit future acts of violence.
6. The Defendant was at least 18 years of age at the time the murders were committed.
When you return to the room, select one of your members to act as presiding juror. The

presiding juror has no greater voting weight but is to preside over your deliberations and be the

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spokesperson for the jury. You should then deliberate and ?nd your verdict.

If it becomes necessary during your deliberations to communicate with me, do so in writing.
I will consult with the parties before responding. No one except for you. the jurors. is to be involved
in your deliberations. Therefore. do not tell anyone, including me. how many of you are votin yes
or no until you have reached a lawful verdict or have been discharged. When you have arrived at a

verdict, the presidingjuror will complete and sign the appropriate verdict form. After you have

reached your verdict. signal the bailiff. The court will then receive your verdict.