Proposed Mississippi Plain Language Model Jury Instructions - Criminal 2768

[Name of defendant] is charged in count ____ with carjacking.

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

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

2A. [Name of defendant] [intentionally/knowingly] and unlawfully took a motor vehicle from

[name of victim]’s immediate actual possession;

OR

2B. [Name of defendant] recklessly and unlawfully took a motor vehicle from [name of victim]’s

immediate actual possession:

A. By using force or violence to ____________________ [describe defendant’s alleged

actions]; or

B. By ____________________ [describe defendant’s alleged actions], whether [name of

victim] resisted or whether [name of defendant] suddenly or secretly took the motor

vehicle; or

C. By putting [name of victim] in fear by ____________________ [describe defendant’s

alleged actions]; or

D. By attempting to use force or violence or to suddenly or secretly take the motor vehicle

or to put [name of victim] in fear by ____________________ [describe defendant’s

alleged actions]; or

E. By ____________________ [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 _____.