Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3441

[Name of defendant] is charged in count ___with unlawfully buying or possessing a metal

beer keg or metal syrup tank.

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] was a scrap metal dealer or other purchaser; and

3. [Name of defendant] [intentionally/knowingly] and unlawfully [bought/purchased/possessed] a

____________ [specify metal beer keg, metal syrup tank used by the soft drink industry, or

reasonably recognizable part of a metal beer keg or metal syrup tank], without a bill of sale from

the manufacturer, soft drink company, or distributor, on the premises that [name of defendant]

used to buy, sell, store, shred, melt, cut, or alter scrap metal; and

4. The ____________ [specify metal beer keg, metal syrup tank used by the soft drink industry,

or reasonably recognizable part of a metal beer keg or metal syrup tank] [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, “scrap metal dealer” means a person who is in the business of paying

money or other compensation for metal property which has served its original economic purpose.

In this instruction, “purchaser” means a person who gives [money/consideration/financial

benefit] in exchange for metal property.