Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3435

[Name of defendant] is charged in count ___ with larceny.

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] [got/obtained] ___________ [specify the personal property] under a lease

or rental agreement; and

3. [Name of defendant] [exercised/used/had] unauthorized control over the _____________

[specify the personal property], intending to deprive [name of owner] from using the

________________ [specify the personal property] by unlawfully:

A. Withholding [name of owner]’s property permanently or for a period of time that

would cause [name of owner] to lose the ____________ [specify the personal property]’s

economic value, use, or benefit; or

B. Withholding the ____________ [specify the personal property] only to return it to

[name of owner] after payment of a reward or other compensation; or

C. [Concealing/Abandoning/Hiding/Disposing of] the ____________ [specify the

personal property] so that it was unlikely that [name of owner] would recover it; or

D. [Selling/Giving/Pledging/Transferring] an interest in the property; and

4. The ____________ [specify the personal property] [was/were] valued at $250.00 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 _____.