Haw. Pattern Jury Instr. (Criminal) 11.06

H.R.S. § 709-906(1)

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

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

of Abuse of Family or Household Members.

A person commits the offense of Abuse of Family or

Household Members if he/she intentionally, knowingly, or

recklessly physically abuses a family or household member.

There are three material elements of the offense of Abuse

of Family and or Household Members, 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 physically abused (name of

complainant); and

2. That, at that time, the Defendant and (name of

complainant) were family or household members; and

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

recklessly as to each of the foregoing elements.

“Family or household member” means spouses or reciprocal

beneficiaries,* former spouses or reciprocal beneficiaries,*

persons in a dating relationship, persons who have a child in

common,** parents, children, persons related by consanguinity,**

and persons jointly residing or formerly residing in the same

dwelling unit.