Del. P.J.I. Crim. No. 11.1325(b)(3)

CRUELTY TO ANIMALS

In order to find Defendant guilty of Cruelty to Animals, you must find the

State proved the following three (3) elements beyond a reasonable doubt:

(1) Defendant [killed/injured] [animal]; belonging to another person;

(2) Defendant acted without [legal privilege/consent of the owner]; and

(3) Defendant acted [intentionally/recklessly].

“Intentionally” means it was Defendant’s conscious objective or purpose to

engage in cruelty to animals.

“Recklessly” means Defendant was aware of and consciously disregarded a

substantial and unjustifiable risk that [animal] would be [neglected/mistreated, etc.]

as the result of Defendant’s conduct. The State must demonstrate the risk was of

such a nature and degree Defendant’s disregard of it was a gross deviation from

the standard of conduct a reasonable person would observe under the same

circumstances.

“Animal” does not include fish, crustacea or mollusca.