Proposed Mississippi Plain Language Model Jury Instructions - Criminal 2737

[Name of defendant] is charged in count ____ with unlawfully taking a child less than 14

years old out of the State of Mississippi or with keeping a child less than 14 years old from

entering the State of Mississippi.

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 child] was less than 14 years old; and

3. There was a court order giving custody of [name of child] to [name of person]; and

4. [Name of defendant] was [name of child]'s non-custodial parent or relative; and

5. [Name of defendant] unlawfully ____________________________ [specify (1) took [name of

child] out of the State of Mississippi or (2) kept [name of child] from entering the State of

Mississippi], intending to violate the court order giving custody of [name of child] to [name of

person],

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 _____.