guilt of an accused individual. Throughout the 1930s and 1940s in California, a panel comprising judges and lawyers drafted pattern jury instructions. These standardized jury instructions were problematic, as they were written using technical language rather than in plain English. In the late 1970s, Robert and Veda Charrow studied jury instructions for comprehensibility, where individuals were asked to verbally summarize pattern jury instructions. The participants accounted for only one-third of pertinent information given in the jury instructions. The Charrows further identified linguistic features of these instructions that made instructions given to member of a jury difficult to understand. After revising the instructions to include a more recognized vocabulary, comprehension rose 47%. Tiersma provides examples of jury instructions in both legal English and plain English. In the Book of Approved Jury Instructions (BAJI) instructions regarding the care of motorists when operating a motor vehicle read: Tiersma points out several confusing terms and formal jargon used in this definition that would be difficult for jury participants to understand. He highlights "to use like care" as being overly formal and "pedestrian" as being atypically defined including individuals using wheelchairs and "motorized quadrangles". The California Jury Instructions: Criminal (CACI) reworked these instructions and read: The CACI instructions are in common language and are more direct. Jury instructions that are more direct have been criticized, saying that utilizing a more recognizable vocabulary would make the instructions less precise in a legal atmosphere. Medical writing In medical writing, plain language serves to meet patients at their level of health literacy. As defined by the Institute of Medicine's report, health literacy is "the degree to which individuals have the capacity to obtain, process, and understand basic health information and services needed to make appropriate health decisions." In April 2004, the Institute of Medicine (IOM) and the Agency for Healthcare Research and Quality (AHRQ) released health literacy reports citing the 1992 National Adult Literacy Survey (NALS) results as a cause for concern. The 1992 NALS indicated that nearly half of Americans demonstrated limited literacy skills. The NALS did not explicitly look at health literacy, but it did cover health-related tasks. In response, researchers developed methods to measure health literacy, such as the Health Activities Literacy Scale (HALS). Many governmental organizations, such as the Centers for Disease Control and Prevention (CDC) and the National Institutes of Health (NIH), continue to research methods and produce materials for implementing plain language