Ala. Pattern Jury Instr. (Criminal) 31-13-14(A)

Dealing in False Identification Documents

The defendant is charged with dealing in false identification papers.

A person commits the crime of dealing in false identification papers if he/she

knowingly reproduces, manufactures, sells, or offers for sale any identification

document which does both of the following:

(1) Simulates, purports to be, or is designed so as to cause others reasonably

to believe it to be an identification document.

(2) Bears a fictitious name or other false information.

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

elements:

1. The defendant reproduced, manufactured, sold, or offered for sale any

identification document [Insert name of document];

2. The document both:

A. Simulated, purported to be, or was designed so as to cause others

reasonably to believe it to be an identification document, and

B. Bore a fictitious name or other false information; (AND)

2. The defendant acted knowingly.

Identification document means any card, certificate, or document or banking

instrument, including, but not limited to, a credit or debit card, which identifies or

purports to identify the bearer of such document, whether or not intended for use as

identification, and includes, but is not limited to, documents purporting to be drivers'

licenses, non-driver identification cards, certified copies of birth, death, marriage, and

divorce certificates, Social Security cards, and employee identification cards.[31-13-

14(e)]

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

described by a statute defining an offense when he is aware that his 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 above elements of dealing in false identification papers, then you

shall find the defendant guilty of the offense of dealing in false identification papers.

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

one or more of the elements of dealing in false identification papers, then you cannot

find the defendant guilty of dealing in false identification papers.

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

those offenses at this point.]