Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3020

[Name of defendant] is charged in count ___ with failing to stop for a law enforcement

officer.

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 law enforcement officer], a law enforcement officer, signaled [name of defendant] to

come to a stop by _______________ [describe officer’s hand, voice, siren, or emergency light

signal]; and

3. [Name of law enforcement officer] was performing [his/her] official law enforcement

[duty/duties] and reasonably believed that [name of defendant] had committed a crime; and

4. [Name of defendant] [intentionally/willfully] and unlawfully refused to come to a stop; and

5. [Name of defendant] unlawfully caused the death of [name of victim] 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 _____.