Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3440

[Name of defendant] is charged in count ___with unlawfully transporting metal property.

If you find beyond a reasonable doubt from the evidence in this case that:

1. On or about [date of alleged crime], in ____________ County;

2A. [Name of defendant] [intentionally/willfully/knowingly] and unlawfully transported

___________ [describe metal property] for [himself/herself/another person] from any point

inside the State of Mississippi to any point outside the State of Mississippi;

OR

2B. [Name of defendant] [intentionally/willfully/knowingly] and unlawfully caused

___________ [describe metal property] to be transported for [himself/herself/another person]

from any point inside the State of Mississippi to any point outside the State of Mississippi; and

3. [Name of defendant] did not report the transportation of the ___________ [describe metal

property] to the sheriff of ___________ County where the ___________ [describe metal

property] was leaving; and

4. The ___________ [describe metal property] [was/were] valued at more than $500.00,

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, “metal property” means materials such as railroad track materials;

copper materials; aluminum materials; electrical, communications, or utility brass; stainless steel

sinks; catalytic converters not attached to a motor vehicle; and metal beer kegs.