IDENTITY - POLICE PHOTOS Model Jury charge NJ Criminal cases
There are in evidence photographs that were used to identify the defendant in this case.
With reference to the photographs submitted into evidence, you will notice that many or all of the photographs appeared to have been taken by a law enforcement agency, or some other government entity.
You are not to consider the fact that the agency obtained a photograph of the defendant as prejudicing him/her in any way. The photographs are not evidence that the defendant has ever been arrested or convicted of any crime. Such photographs come into the hands of law enforcement from a variety of sources, including but not limited to driver's license applications, passports, ABC identification cards, various forms of government employment, private employment requiring state regulation, including but not limited to casino license applications, security guard applications, etc., or from a variety of other sources totally unconnected with criminal activity.