Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3442

[Name of defendant] is charged in count ___with unlawfully selling a bronze vase or

marker.

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] [intentionally/willfully/knowingly] and unlawfully sold a bronze

____________ [specify vase, marker, memorial, statue, plaque, or other bronze object], which

was used at a cemetery or other place where people are interred or memorialized, to [name of

scrap metal dealer], who was a scrap metal dealer; and

3. [Name of scrap metal dealer] did not know where the ____________ [specify vase, marker,

memorial, statue, plaque, or other bronze object] came from and did not give notice to

____________ [specify the municipal or county law enforcement agency where the dealer is

located]; and

4. The ____________ [specify vase, marker, memorial, statue, plaque, or other bronze object]

was 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.