The Supreme Court of the United States has held that a state criminal trial judge has a constitutional obligation, on a defendant's request, to instruct a jury that no inference of guilt may be drawn from a defendant's failure to testify.
Carter v. Kentucky, 101 S. Ct. 1112 (1981).
Terry J. Trexler,
Constitutional Law - Fifth and Fourteenth Amendments - Privilege Against Self-Incrimination - Procedure in State Criminal Trials - Jury Instructions,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol20/iss1/9