Ill. Pattern Jury Instr. (Criminal) 11.50

To sustain the charge of threatening a [(public official) (human service provider)] the

State must prove the following propositions:

First Proposition: That the defendant knowingly delivered or conveyed, directly or

indirectly, to a [(public official) (human service provider)] by any means a communication

containing a threat

[1] that would place the [(public official) (human service provider)] [or a member of his

immediate family] in reasonable apprehension of immediate or future [(bodily harm) (sexual

assault) (confinement) (restraint)];

[or]

[2] that would place the [(public official) (human service provider)] [or a member of his

immediate family] in reasonable apprehension that damage will occur to property in the custody,

care, or control of the [(public official) (human service provider)] [or his immediate family];

and

Second Proposition: That ____ was a [(public official) (human service provider)] at the

time of the threat;

and

[1] Third Proposition: That the threat was conveyed because of the performance or

nonperformance of some [(public duty) (duty as a human service provider)].

[or]

[2] Third Proposition: That the threat was conveyed because of the hostility of the

person making the threat toward the status or position of the [(public official) (human service

provider)].

[or]

[3] Third Proposition: That the threat was conveyed because of any other factor relating

to the official’s public existence.

and

Fourth Proposition: That when the defendant conveyed the threat, he knew ____ was

then [(a public official) (human service provider)].

[and]

[Fifth Proposition: That the threat to a [(sworn law enforcement officer) (social worker)

(caseworker) (investigator) (human service provider)] contained specific facts indicative of a

unique threat to the [(sworn law enforcement officer) (social worker) (caseworker) (investigator)

(human service provider) [(family) (property) of the (sworn law enforcement officer) (social

worker) (caseworker) (investigator) (human service provider)]] and not a generalized threat of

harm.]

If you find from your consideration of all the evidence that each one of these propositions

has been proved beyond a reasonable doubt, you should find the defendant guilty.

If you find from your consideration of all the evidence that any one of these propositions

has not been proved beyond a reasonable doubt, you should find the defendant not guilty.