Ala. Pattern Jury Instr. (Criminal) 13A-10-152

Terrorism

The defendant is charged with terrorism.

A person commits the crime of terrorism if, with intent to intimidate or coerce a

civilian population, influence the policy of a unit of government by intimidation or coercion,

or affect the conduct of a unit of government by murder, assassination, or kidnapping,

he/she commits [name specified offense].

To convict, the State must prove beyond a reasonable doubt each of the following

elements:

(1) The defendant committed [name specified offense]; (AND)

(2) The defendant did so with intent to [read as appropriate]:

(a) Intimidate or coerce a civilian population;

(b) Influence th e policy of a unit of government by intimidation or

coercion; (OR)

(c) Affect the conduct of a unit of government by [read as appropriate]:

murder, assassination, or kidnapping.

[Insert instructions for specified offense]

[Read as appropriate]: [Insert instruction for Attempt 13A-4-2 or Conspiracy

13A-4-3.]

[Read as appropriate] : An act of terrorism is an act or acts constituting [name

specified offense] for which a person may be convicted in the criminal courts of this

state, or an act or acts constituting an offense in any other jurisdiction within or outside

the territorial boundaries of the United States which contains all of the essential elements

of a specified offense, that is intended to do the following:

a. Intimidate or coerce a civilian population;

b. Influence the policy of a unit of government by intimidation or coercion; (OR)

c. Affect the conduct of a unit of government by murder, assassination, or

kidnapping. [13A-10-151(1)]

[Read as appropriate] : [Insert in structions for murder, assassination, or

kidnapping.]

A person acts intentionally with respect to a result or to conduct described by a

statute defining an offense when his/her purpose is to cause that result or to engage in

that conduct. [13A-2-2(1)]

If you find from the evidence that the State has proved beyond a reasonable doubt

each of the above elements of terrorism, then you shall find the defendant guilty of

terrorism.

If you find that the State has failed to prove any one or more of the elemen ts of

terrorism, then you cannot find the defendant guilty of terrorism.

[If lesser-included offenses are included, the Court should instruct on those

offenses at this point.]