Haw. Pattern Jury Instr. (Criminal) 15.04

H.R.S. § 134-6(d)

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

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

of Loaded Firearm on a Public Highway.

A person commits the offense of Loaded Firearm on a Public

Highway if, while on a public highway, he/she [carries on

his/her person] [has in his/her possession] [carries in a

vehicle] a firearm loaded with ammunition, without a license to

carry.

There are seven material elements of the offense of Loaded

Firearm on a Public Highway, each of which the prosecution must

prove beyond a reasonable doubt.

These seven elements are:

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

(name of county), the Defendant knowingly [carried on his/her

person] [had in his/her possession] [carried in a vehicle] the

object in question; and

2. That the object in question was a firearm loaded with

ammunition; and

3. That, at the time he/she [carried] [possessed] the

object in question, the Defendant believed, knew, or recklessly

disregarded the substantial and unjustifiable risk, that the

object was a firearm loaded with ammunition; and

4. That, at that time, the Defendant was on a public

highway; and

5. That, at that time, the Defendant believed, knew, or

recklessly disregarded the substantial and unjustifiable risk,

that he/she was on a public highway; and

6. That, at that time, the Defendant did not have a

license to carry; and

7. That, at that time, the Defendant believed, knew, or

recklessly disregarded the substantial and unjustifiable risk,

that he/she did not have a license to carry.

“License to carry” means a license to carry a pistol or

revolver and ammunition therefor issued by the chief of police

of the [City and] County of (name of county).