Haw. Pattern Jury Instr. (Criminal) 10.24

H.R.S. § 708-836

[In Count (count number) of the Indictment/Complaint, the]

[The] Defendant, (defendant’s name), is charged with the offense

of Unauthorized Control of Propelled Vehicle.

A person commits the offense of Unauthorized Control of

Propelled Vehicle if he/she intentionally or knowingly* exerts

unauthorized control over another’s propelled vehicle by

operating the vehicle without the owner’s consent.

There are three material elements of the offense of

Unauthorized Control of Propelled Vehicle, each of which the

prosecution must prove beyond a reasonable doubt.

These three elements are:

1. That, on or about (date) in the [City and] County of

(name of county), the Defendant exerted unauthorized control

over another’s propelled vehicle; and

2. That the Defendant did so by operating the vehicle

without the owner’s consent; and

3. That the Defendant did so intentionally or knowingly*.

“Owner” means the [registered owner of the propelled

vehicle or the unrecorded owner of the vehicle pending transfer

of ownership][legal owner, provided there is no registered owner

of the propelled vehicle or unrecorded owner of the vehicle

pending transfer of ownership].

“Propelled vehicle” means an automobile, airplane,

motorcycle, motorboat, or other motor-propelled vehicle.