CALCRIM No. 2221

The defendant is charged [in Count] with driving without a

license [in violation of Vehicle Code section 12500(a)].

To prove that the defendant is guilty of this crime, the People must

prove that:

1. The defendant drove a motor vehicle on a highway;

[AND]

2. When the defendant drove, (he/she) did not hold a valid

California driver’s license(;/.)

<Give element 3 when instructing on statutory exemption.>

[AND

3. The defendant was not excused from the requirement to have a

California driver’s license.]

Whether the defendant was properly licensed is a matter within (his/her)

own knowledge. The defendant must produce evidence tending to show

that (he/she) did hold a valid driver’s license. If the evidence raises in

your mind a reasonable doubt about whether the defendant held a valid

driver’s license, you must find the defendant not guilty of this crime.

[A motor vehicle includes a (passenger vehicle/motorcycle/motor scooter/

bus/school bus/commercial vehicle/truck tractor and trailer/

<insert other type of motor vehicle>).]

[The term highway describes any area publicly maintained and open to

the public for purposes of vehicular travel, and includes a street.]

[The term[s] (motor vehicle/ [and] highway) (is/are) defined in another

instruction to which you should refer.]

New January 2006