Proposed Mississippi Plain Language Model Jury Instructions - Criminal 4013

[Name of defendant] is charged in count ___ with having sexual intercourse with a

female who was more than 18 years old by a pretend or false marriage or promise of marriage.

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 person] was a female more than eighteen (18) years old and of previous chaste

character; and

3. [Name of defendant] [obtained/had] [carnal knowledge/sexual penetration] with [name of

person] by a ____________________ [specify (1) [false/feigned] or pretend marriage or (2)

[false/feigned] promise of marriage],

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, “carnal knowledge” means the slightest penetration of the sexual organ

of the female by the sexual organ of the male. It is not necessary that the vagina be entered or that

the hymen be ruptured; the entering of the vulva or labia is sufficient.

In this instruction, “sexual penetration” means any touching or penetrating of a person's

anal, genital, or oral openings by [name of defendant] or by [name of defendant] inserting an

object into a person's anal, genital or oral openings.