Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3426

[Name of defendant] is charged in count ___ with larceny by severing a gate, fence,

railing, or other improvement.

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 cut or severed [a/an] __________ [specify the gate, fence,

railing, or other improvement], which was attached to a building; and

3. [Name of defendant] unlawfully took and converted the __________ [specify the gate, fence,

railing, or other improvement] for [his/her] own use, intending to steal the __________ [specify

the gate, fence, railing, or other improvement]; and

4. The __________ [specify the gate, fence, railing, or other improvement] [was/were] valued at

$500.00 or more,

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 _____.