VA VMJI 33.850 Accidental Killing
Virginia Model Jury Instruction (2013)
33.850 Accidental Killing
Where the defense is that the killing was an accident, the defendant is not required to prove this fact. The burden is on the Commonwealth to prove beyond a reasonable doubt that the killing was not accidental. If after considering all the evidence you have a reasonable doubt whether the killing was accidental or intentional, then you shall find the defendant not guilty.