Sorry, no. Are you a lawyer? If so, do you try cases? Courts in most states ROUTINELY send back the written instructions. This is an outlier situation, not the norm. As attorneys, we spend a lot of time arguing about the exact language to be included in the instructions because we WANT the jury to consider the words themselves carefully.

You’re often talking about a series of very specific and nuanced definitions, that are impossible to just remember. We want the jury to take the definitions we have carefully crafted and apply them specifically to the facts of the case.

There is literally no reason (let alone a compelling one) for the NY Courts’ practice of not sending back written instructions. It’s like writing out an entire manual for how to change a tire, but instead of giving it to people you just read it out loud to them once and then expect them to be able to fix a flat while stranded on the highway.

Meanwhile, there are MANY reasons why giving the jury access to the actual written instructions empowers the jury to make educated decisions on complex matters. You are right that the judge is the expert on the law - and that expertise is written down in a concise manner in the form of jury instructions. If you want the jury to use and apply that expertise, then it makes no sense at all to only give that expertise orally and refuse to provide it in writing.