Proposed Mississippi Plain Language Model Jury Instructions - Criminal 2649

[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

___________________________________ [describe defendant’s alleged actions], which was

likely to kill or seriously injure __________ [name of victim]; 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)]; and

4. [Name of defendant] was previously convicted of _______________ [specify violation of §

97-3-7(3)] in __________ [list court and details of previous conviction] on __________ [list date

of previous conviction] and of _______________ [specify violation of § 97-3-7(3)] in

__________ [list court and details of previous conviction] on __________ [list date of previous

conviction], both occurring within five (5) years of _____________ [date of alleged crime],

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.