Ala. Pattern Jury Instr. (Criminal) 15-20A-18(D)

Failing to Relinquish Identification

(Adult)

The defendant is charged with failing to relinquish a driver license or identification

card upon obtaining a driver license or identification card as an adult sex offender bearing

a designation that enables law enforcement officers to identify the licensee as a sex

offender.

A person commits the crime of failing to relinquish a driver license or identification

card upon obtaining a driver license or identification card as an adult sex offender bearing

a designation that enables law enforcement officers to identify the licensee as a sex

offender if he/she is an adult sex offender and, upon obtaining or renewing a driver license

or identification card bearing a designation that enables law enforcement officers to

identify the licensee as a sex offender, he/she fails to relinquish to the Alabama State

Law Enforcement Agenc y any driver license or identification card previously issued to

him/her which does not bear any designation enabling law enforcement officers to identify

the licensee as a sex offender.

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

elements:

(1) The defendant was an adult sex offender;

(2) The defendant, upon obtaining or renewing a driver license or identification

card bearing a designation that enables law enforcement officers to identify

the licensee as a sex offender, fails to relinquish to the Alabama State Law

Enforcement Agency any driver license or identification card previously

issued to him/her which does not bear any designation enabling law

enforcement officers to identify the licensee as a sex offender; (AND)

(3) The defendant did so knowingly.

An adult sex offender is a person convicted of a sex offense. [15-20A-4(1)]

A sex offense includes any of the following offenses: [Insert all appropriate from

15-20A-5].

A conviction is a verdict or finding of guilt as the result of a trial, a plea of guilty, a

plea of nolo contendere, or an Alford plea regardless of whether adjudication was

withheld. Conviction includes, but is not limited to, a conviction in a United States territory,

a conviction in a fed eral or military tribunal, including a court martial conducted by the

Armed Forces of the United States, a conviction for an offense committed on an Indian

reservation or other federal property, a conviction in any state of the United States or a

conviction in a foreign country if the foreign country's judicial system is such that it

satisfies minimum due process set forth in the guidelines under Section 111(5)(B) of

Public Law 109 -248. Cases on appeal are deemed convictions until reversed or

overturned. [15-20A-4(4)]

A person acts knowingly with respect to conduct or to a circumstance described

by a statute defining an offense he/she is aware that his/her conduct is of that nature or

that the circumstance exists. [13A-2-2(2)]

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

each of the elements of the offense, then you shall find the defendant guilty of this offense.

If you find that the State has failed to prove beyond a reasonable doubt any one

or more of the elemen ts of the offense, then you cannot find the def endant guilty of this

offense.