Proposed Mississippi Plain Language Model Jury Instructions - Criminal 2500

[Name of defendant] is charged in count ___ with conspiracy to ________________

[specify crime or action listed in § 97-1-1].

If you find beyond a reasonable doubt from the evidence in this case that:

1. On or about [date of alleged crime], in ____________ County;

2. [Name of defendant] and [name(s) of co-conspirator(s)] unlawfully [agreed/conspired]:

A. To commit ____________ [specify crime]; or

B. To have [name of victim] falsely arrested [and/or] indicted for ____________ [specify

the crime]; or

C. To file a lawsuit against [name of victim] falsely alleging ____________ [specify

cause of action]; or

D. To cheat [name of victim] out of ____________ [specify property] by unlawfully

_____________________ [describe defendant’s alleged actions]; or

E. To keep [name of victim] from working as a __________ [specify job or profession] or

from operating [his/her] business by _________________________ [describe

defendant’s alleged actions]; or

F. To _________________________ [describe defendant’s alleged actions], which would

violate public health, public morals, trade, commerce, obstruct justice, [and/or] the

enforcement of laws; or

G. To violate or overthrow the laws of Mississippi using violence, threats, or intimidation

by ______________________________ [describe defendant’s alleged actions]; or

H. To accomplish _____________________ [describe defendant’s intent] by unlawfully

_________________________ [describe defendant’s alleged actions],

then you shall find [name of defendant] guilty as charged.

If the State did not prove any one of the above listed elements beyond a reasonable doubt,

then you shall find [name of defendant] not guilty of count ___.