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

Vital Records Identity Fraud

The defendant is charged with vital records identity fraud.

A person commits the crime of v ital records identity fraud related to birth,

death, marriage, and divorce certificates if he/she does any of the following:

(1) Supplies false information intending that the information be used to obtain a

certified copy of a vital record.

(2) Makes, counterfeits, alters, amends, or mutilates any certified copy of a vital

record without lawful authority and with the intent to deceive.

(3) Obtains, possesses, uses, sells, or furnishes, or attempts to obtain,

possess, or furnish to another a certified copy of a vital record, with the

intent to deceive.

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

following elements:

1. [Read as appropriate based on the facts]:

The defendant supplied false information intending that the information

be used to obtain a certified copy of a vital record; [OR]

The defendant made, counterfeited, altered, amended, or mutilated

any certified copy of a vital record without lawful authority and with

the intent to deceive; [OR]

The defendant obtained, possessed, used, sold, or furnished, or

attempted to obtain, possess, or furnish to another a certified copy of a

vital record, with the intent to deceive;

(AND)

2. The defendant acted knowingly.

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 vital records identity fraud, then you shall find

the defendant guilty of the offense of vital records identity fraud.

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

one or more of the elements of dealing in vital records identity fraud, then you

cannot find the defendant guilty of vital records identity fraud.

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

those offenses at this point.]