Ill. Pattern Jury Instr. (Criminal) 11.84

To sustain the charge of cemetery vandalism, the State must prove the following

proposition:

[1] That the defendant[, without proper legal authority,] wilfully and knowingly [

(destroyed) (damaged)] the remains of a deceased human being.

[or]

[2] That the defendant[, without proper legal authority,] wilfully and knowingly removed

any portion of the remains of a deceased human being from a [(burial ground where skeletal

remains are buried) (grave) (crypt) (vault) (mausoleum) (repository of human remains)].

[or]

[3] That the defendant[, without proper legal authority,] wilfully and knowingly

desecrated human remains.

[or]

[4] That the defendant[, without proper legal authority,] wilfully and knowingly [

(obliterated) (vandalized) (desecrated)]

[a] a [(burial ground where skeletal remains are buried) (grave) (crypt) (vault)

(mausoleum) (repository of human remains)] and the amount of damage was [

(less than $500) (at least $500 and less than $10,000) (at least $10,000 and less

than $100,000) ($100,000 or more)].

[b] a park or other area clearly designated to preserve and perpetuate the memory

of a deceased person or group of persons and the amount of damage was [(less

than $500) (at least $500 and less than $10,000) (at least $10,000 and less than

$100,000) ($100,000 or more)].

[or]

[c] [(plants) (trees) (shrubs) (flowers)] located upon or around a repository for

human remains or within a human graveyard or cemetery and the amount of

damage was [(less than $500) (at least $500 and less than $10,000) (at least

$10,000 and less than $100,000) ($100,000 or more)].

[or]

[d] [(fence) (rail) (curb) [or structure of a similar nature]] intended for the

protection or ornamentation of any [(tomb) (monument) (gravestone) [or other

structure of like character]] and the amount of damage was [(less than $500) (at

least $500 and less than $10,000) (at least $10,000 and less than $100,000)

($100,000 or more)].

[or]

[5] That the defendant[, without proper legal authority,] wilfully and knowingly [

(defaced) (vandalized) (injured) (removed)] a [(gravestone or other memorial) (monument)

(marker commemorating a deceased person [or group of persons] )] [whether located within or

outside of a recognized [(cemetery) (memorial park) (battlefield)]] and damaged [(at least one

but no more than 4 gravestones) (at least 5 but no more than 10 gravestones) (more than 10

gravestones)].

If you find from your consideration of all the evidence that this proposition has been

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

If you find from your consideration of all the evidence that this proposition has not been

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