Proposed Mississippi Plain Language Model Jury Instructions - Criminal 2758

[Name of defendant] is charged in count ___ with aggravated stalking.

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

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

2A. [Name of defendant] [intentionally/purposely] and unlawfully

______________________________ [describe defendant’s alleged course of conduct] towards

[name of victim];

OR

2B. [Name of defendant] credibly and unlawfully threatened [name of victim];

OR

2C. [Name of defendant] ______________________________ [describe defendant’s alleged

actions] towards [name of victim], which would make a reasonable person fear for [his/her] own

safety, or for the safety of another person, or fear harm or damage to [his/her] property; and

3A. When [name of defendant] ______________________________ [describe defendant’s

alleged actions], [he/she] unlawfully [displayed/showed/used] a deadly weapon, intending to

make [name of victim] reasonably fear death or being injured or someone else being injured;

OR

3B. [Name of defendant] was previously convicted of ___________________ [specify violation

of § 97-3-107] in ___________ [list court and details of previous conviction] on __________

[list date of previous conviction], which is within seven (7) years of ______________ [date(s) of

alleged crime];

OR

3C. When [name of defendant] _____________________________ [describe defendant’s

alleged actions], [he/she] was required to be registered as a sex offender pursuant to

_______________________ [specify state, federal, military, or tribal law requiring the defendant

to be registered] and [name of victim] was less than 18 years old,

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 _____.