Ill. Pattern Jury Instr. (Criminal) 9.34

To sustain the charge of sexual relations within families, the State must prove the

following propositions:

First Proposition: That the defendant committed an act of sexual penetration upon ____;

and

Second Proposition: That the defendant knew that [(he) (she)] was related to ____ as [

(brother) (sister)] either of the whole-blood or of the half-blood.

[or]

First Proposition: That the defendant committed an act of sexual penetration upon ____;

and

Second Proposition: That the defendant knew that [(he) (she)] was related to ____ as [

(father) (mother)] regardless of legitimacy and regardless of whether ____ is of the whole -blood

or adopted; and

Third Proposition: That ____ was 18 years of age or over when the act was committed.

[or]

First Proposition: That the defendant committed an act of sexual penetration upon ____;

and

Second Proposition: That the defendant knew that [(he) (she)] was related to ____ as [

(stepfather) (stepmother)]; and

Third Proposition: That ____ was 18 years of age or over when the act was committed.

If you find from your consideration of all the evidence that each 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.