Ill. Pattern Jury Instr. (Criminal) 7.19B

Than The Pregnant Woman—Transferred Intent

To sustain the charge of voluntary manslaughter of an unborn child, the State must prove

the following propositions:

First Proposition: That the defendant performed the acts which caused the death of the

unborn child of ____; and

Second Proposition: That when the defendant did so, he

[1] intended to kill or do great bodily harm to a person other than ____;

[or]

[2] knew that his acts would cause death to a person other than ____;

[or]

[3] knew that his acts created a strong probability of death or great bodily harm to a

person other than _____;

and

Third Proposition: That the defendant, at the time he performed the acts which caused the

death of the unborn child of ____, acted under a sudden and intense passion resulting from

serious provocation by the person he endeavors to kill, but he negligently or accidentally killed

the unborn child of ____.

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.