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d 875, 880 (Minn. 2024) (stating that “[t]he State does not have the burden of removing all doubt, but of removing all reasonable doubt” (quoting Al-Naseer, d at 473)); (stating that proof beyond reasonable doubt “does not require the case to be proved beyond all possibility of doubt,” but is based on reason and common sense, and approving description of reasonable doubt as the amount of proof that ordinary men and women rely upon in making their own most important

Jury instructions are erroneous if they “confuse, mislead, or materially misstate the law.” -02 (Minn. 2004).

District courts “are afforded broad discretion and considerable latitude in choosing the language of jury instructions.”

d 398, 400 (Minn. 2004).

“[I]t is error if the 5 instructions confuse, mislead, or materially misstate the law.” d 398, 401- 02 (Minn. 2004).

District courts are afforded “broad discretion and considerable latitude in choosing the language of jury instructions.”

(quoting State v. Smith , ).

-03 (Minn. 2004 ) (concluding that reasonable -doubt instruction that included statement that reasonable dou bt does not require proof “to a mathematical certainty” was not plainly erroneous).

“Although courts may favor the use of CRIMJIG s, their use is not mandatory.” (stating that although district court may preferably use CRIMJIG, jury instruction fairly and adequately explained law and was not error).

Third, d 398 (2004), rather than using the pattern instruction from the Criminal Jury Instruction Guide.

The district court is not required to use the standard jury instructions, and it may tailor the 4 instructions to fit the facts of each case, review denied (Minn. June 15, 1994).

District courts enjoy “broad discretion and considerable latitude in choosing the language of jury instructions.”

Additionally, while it is “well settled that jury instructions must define the crime charged and explain the elements” of that crime to the jury, id., we nevertheless give district courts “broad discretion and considerable latitude in choosing the language of jury instructions,”

When reviewing jury instructions, error exists “if the instructions confuse, mislead, or materially misstate the law.” -02 (Minn.2004); see Griller, d at 740 .

“We analyze jury instructions ‘with the understanding that trial courts possess significant discretion in the selection of instruction language and that instructions must be read as a whole to determine whether they accurately describe the law.’ ” Earl, d at 720 ().

We analyze jury instructions “with the understanding that trial courts possess significant discretion in the selection of instruction language and that instructions must be read as a whole to determine whether they accurately describe the law.”