Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3445

[Name of defendant] is charged in count ___with failing to register as a scrap metal

dealer.

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 ____________________

[specify (1) who [bought/purchased] scrap metal property; (2) who dealt in scrap metal property;

or (3) who worked in the scrap metal business]; and

3. [Name of defendant] unlawfully failed to register with the Mississippi Secretary of State; and

4. [Name of defendant] was previously convicted of unlawfully failing to register with the

Mississippi Secretary of State in ___________ [list court and details of previous conviction] on

__________ [list date of previous conviction] [and of unlawfully failing to register with the

Mississippi Secretary of State in ___________ [list court and details of previous conviction] on

__________ [list date of previous conviction]],

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.