Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3444

[Name of defendant] is charged in count ___with unlawfully buying metal property from

a person who [is/was] less than 18 years old.

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/willfully/knowingly] and unlawfully bought metal property

from [name of person], who was less than 18 years old; and

4. The metal property 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, “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.

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.