Proposed Mississippi Plain Language Model Jury Instructions - Criminal 2646

[Name of defendant] is charged in count ___ with simple domestic violence.

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] negligently and unlawfully injured [name of victim] by using a deadly

weapon to __________________________________ [describe defendant’s alleged actions]; and

3. When [name of defendant] negligently and unlawfully injured [name of victim], [name of

victim] was [his/her/a/the] ___________________________ [specify relationship of victim

listed in § 97-3-7(3)],

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 ___.

Definition(s) in this Instruction -

In this instruction, “negligently” means doing something that a reasonably careful person

would not do under similar circumstances or failing to do something that a reasonably careful

person would do under similar circumstances.

In this instruction, “deadly weapon” means an object, article, or means which, when used

as a weapon under the existing circumstances, is reasonably capable or likely to produce death or

serious bodily harm to another person.