simple four-part template (derived from the California Jury Instructions) for evaluating eyewitnesses. If it can be established that (1) a witness was actually present to see the event, (2) can be corroborated (even in a limited way) by another witness or additional evidence, (3) has not changed his story but has been honest and accurate over time, and (4) doesn’t possess a bias that might cause him to lie, you are to consider the witness reliable.

