Ill. Pattern Jury Instr. (Criminal) 8.16

To sustain the charge of child abduction, the State must prove the following propositions:

[1] First Proposition: That, at the time of the alleged violation, [(child)] was [(under the

age of 18 years) (a person with a severe or profound intellectual disability)]; and

Second Proposition: That the defendant [(concealed [(child)]) (detained [(child)])

(removed [(child)] from the jurisdiction of the court)]; and

Third Proposition: That when the defendant did so, there was a court order granting

[(sole) (joint)] [(custody) (care) (possession)] of [(child)] to another; and

Fourth Proposition: That when he did so, the defendant intended to violate any terms of

that court order.

[or]

[2] First Proposition: That, at the time of the alleged violation, [(child)] was [(under the

age of 18 years) (a person with a severe or profound intellectual disability)]; and

Second Proposition: That the defendant [(concealed [(child)]) (detained [(child)])

(removed [(child)] from the jurisdiction of the court)]; and

Third Proposition: That when the defendant did so, there was a court order that

prohibited him from [(concealing [(child)]) (detaining [(child)]) (removing [(child)] from the

jurisdiction of the court)]; and

Fourth Proposition: That when he did so, the defendant intended to violate that order.

[or]

[3] First Proposition: That, at the time of the alleged violation, [(child)] was [(under the

age of 18 years) (a person with a severe or profound intellectual disability)]; and

Second Proposition: That the defendant was [(child)]’s putative father; and,

Third Proposition: That the defendant’s paternity of [(child)] [(had not been legally

established) (had been legally established in a court proceeding where no custody order had been

entered)]; and

Fourth Proposition: That the defendant intentionally [(concealed) (detained) (removed)]

[(child)] without the consent of [(mother) (lawful custodian)].

[or]

[3a] First Proposition: That, at the time of the alleged violation, [(child)] was [(under the

age of 18 years) (a person with a severe or profound intellectual disability)]; and

Second Proposition: That the defendant was [(child)]’s mother; and

Third Proposition: That the defendant intentionally [(concealed) (removed)] [(child)]

from [(unadjudicated father)] who provided sole ongoing care and custody of [(child)] in

[(mother)]’s absence; and

Fourth Proposition: That de fendant had previously [(abandoned) (relinquished custody

of)] [(child)].

[or]

[4] First Proposition: That, at the time of the alleged violation, [(child)] was [(under the

age of 18 years) (a person with a severe or profound intellectual disability)]; and

Second Proposition: That the defendant intentionally [(concealed) (removed)] [(child)]

from [(parent)]; and

Third Proposition: That at the time the defendant did so, defendant had [(filed a petition) (been

served with process)] in an action affecting [(marriage) (paternity)]; and

Fourth Proposition: That at the time the defendant did so, no temporary or final order

determining custody had issued.

[or]

[5] First Proposition: That, at the time of the alleged violation, [(child)] was [(under the

age of 18 years) (a person with a severe or profound intellectual disability)]; and

Second Proposition: That the defendant intentionally [(failed to return) (refused to return)

(impeded the return of)] [(child)] to [(lawful custodian)] in Illinois; and

Third Proposition: That at the time the defendant did so, visitation rights outside the State

of Illinois had expired.

[or]

[6] First Proposition: That, at the time of the alleged violation, [(child)] was [(under the

age of 18 years) (a person with a severe or profound intellectual disability)]; and

Second Proposition: That the defendant is [(child)]’s parent; and

Third Proposition: That the defendant [(is) (was)] married to [(child)]’s other parent; and

Fourth Proposition: That the defendant knowingly concealed [(child)] for 15 days; and

Fifth Proposition: That at the time the defendant did so, there was no court order of

custody; and

Sixth Proposition: That the defendant failed to make reasonable attempts within the 15

day period to notify [(child)]’s other parent as to [(child)]’s specific whereabouts, including

[(notifying the other parent of a means by which to contact [(child)]) (arranging reasonable

visitation with [(child)]) (arranging contact with [(child)])].

[or]

[7] First Proposition: That, at the time of the violation, [(child)] was [(under the age of

18 years) (a person with a severe or profound intellectual disability)]; and

Second Proposition: That the defendant is [(child)]’s parent; and

Third Proposition: That the defendant [(is) (was)] married to [(child)]’s other parent; and

Fourth Proposition: That the defendant knowingly [(concealed) (detained) (removed)]

[(child)]; and

Fifth Proposition: That when the defendant did so, he [(used physical force) (threatened

physical force)]; and

Sixth Proposition: That when the defendant did so, there was no court order of custody.

[or]

[8] First Proposition: That, at the time of the violation, [(child)] was [(under the age of

18 years) (a person with a severe or profound intellectual disability)]; and

Second Proposition: That the defendant knowingly [(concealed) (detained) (removed)]

[(child)]; and

Third Proposition: That the defendant did so for [(payment) (promise of payment)]; and

Fourth Proposition: That the defendant did so at the instruction of a person who had no

legal right to custody of [(child)].

[or]

[9] First Proposition: That, at the time of the violation, [(child)] was [(under the age of

18 years) (a person with a severe or profound intellectual disability)]; and

Second Proposition: That [(child)] had been removed from another State; and

Third Proposition: That the defendant knowingly retained [(child)] in the State of Illinois

for 30 days; and

Fourth Proposition: That the defendant did so [(without the consent of the [(lawful

custodian)]) (in violation of a court order of custody)].

[or]

[10] First Proposition: That [(child)] [(was under the age of 17 years) (was traveling to or

from a primary or secondary school)]; and

Second Proposition: That the defendant intentionally [(lured) (attempted to lure)]

[(child)] into a [(motor vehicle) (building) (house trailer) (dwelling place)]; and

Third Proposition: That the defendant did so without the consent of [(parent) (lawful

custodian)]; and

Fourth Proposition: That the defendant did so for other than a lawful purpose.

[or]

[11] First Proposition: That, at the time of the violation, [(child)] was [(under the age of

18 years) (a person with a severe or profound intellectual disability)]; and

Second Proposition: That the defendant knowingly [([(destroyed) (altered) (concealed)

(disguised)] physical evidence) (furnished false information)]; and

Third Proposition: That the defendant did so with intent to [(obstruct) (prevent)] efforts

to locate the child victim of a child abduction.

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.