Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3412

[Name of defendant] is charged in count ___ with burglary in such a way that is likely to

terrorize a person inside the dwelling house.

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. Intending to commit the crime of _____________ [specify the alleged crime] inside a dwelling

house, [name of defendant] unlawfully broke into and entered [an/the] _______________

[specify dwelling house or interior door of a dwelling house] owned by [name of owner] and

located at __________________________ [specify address of dwelling house], in a way that was

likely to terrorize [name of person], who was inside the dwelling house,

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, “broke into” means any act or force, however slight, used to enter

through any usual or unusual place of entry, whether open, partly open, or closed.

In this instruction, “entered” means the act of making one’s way into a dwelling house.

In this instruction, “dwelling house” means [a/an] apartment, building, house, or room

which the owner considers to be [his/her] dwelling or in which [he/she] intends to live. Any

building or structure connected to a dwelling house is considered part of the dwelling house.