Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3735

[Name of defendant] is charged in count ___ with home repair fraud.

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/knowingly] and unlawfully misrepresented

[himself/herself/another person] to be [a/an] __________________ [specify employee or agent

of the federal, state, or municipal government; or employee or agent of a governmental unit; or

an employee or agent of a public utility], intending to cause [name of person] to enter into [a/an]

[agreement/contract] with [name of defendant] or another person for home repair; and

3. [Name of defendant] was previously convicted of __________________________ [specify

violation of § 97-23-103] 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 in count ___.

Definition(s) in this Instruction:

In this instruction, “home repair” means fixing, replacing, altering, converting,

modernizing, or improving real property primarily used as a residence, or building or making an

addition to real property primarily used as a residence.