https://www.thenationalliteracyinstitute.com/2024-2025-liter... (“54% of U.S. adults read below the equivalent of a sixth-grade level”)

Assessing the Readability of Capital Pattern Jury Instructions - https://docs.rwu.edu/cgi/viewcontent.cgi?article=1207&contex... (2013)

"Plain English" Jury Instructions: Why They’re Still Needed And What The Appellate Community Can Do To Help - https://www.floridabar.org/the-florida-bar-journal/plain-eng... (2004)

> The average reading level of American parents of young children is 7th or 8th grade.

> About one in every four Americans (25 percent) is a high school dropout.

> About half (45 percent) have gone to college for some period of time, but fewer than one in six (15 percent) have a college degree.

> Nearly 50 percent of the Americans surveyed cannot read well enough to find a single piece of information in a short publication, nor can they make low-level inferences based on what they read.