Proposed Mississippi Plain Language Model Jury Instructions - Criminal 2809

[Name of defendant] is charged in count ____ with receiving materials which depict a

child less than 18 years old engaged in sexual conduct and intending to sell or distribute those

materials.

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] unlawfully received a ____________ [specify photograph, drawing, film,

videotape, or other depiction] of an actual child, who was less than 18 years old and who was

engaged in sexual conduct, intending to [distribute/distribute for sale/sell/attempt to sell],

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, “sexual conduct” means real or pretend (1) sexual intercourse,

including genital to genital, oral to genital, anal to genital, or oral to anal intercourse, between

people of the same or opposite sex; (2) bestiality; (3) masturbation; (4) sadistic or masochistic

abuse; (5) sexually showing the genitals or pubic area of any person; or (6) sexually touching the

genitals, pubic area, buttocks, anus, or breast.