Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3443

[Name of defendant] is charged in count ___with unlawfully buying 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] was a scrap metal dealer; and

3. [Name of defendant] [intentionally/willfully/knowingly] and unlawfully [bought/purchased] 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; and

4. [Name of defendant] 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.