Proposed Mississippi Plain Language Model Jury Instructions - Criminal 4500

[Name of defendant] is charged in count ___ with carrying a concealed weapon.

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] unlawfully carried a [partly/completely] concealed ____________

[specify bowie knife, dirk knife, butcher knife, switchblade knife, metallic knuckles, blackjack,

slingshot, pistol, revolver, rifle with a barrel less than sixteen (16) inches long, or shotgun with a

barrel less than eighteen (18) inches long, machine gun, or fully automatic firearm, or deadly

weapon, or muffler or silencer for a firearm]; and

3. [Name of defendant] was previously convicted of _____________________ [specify violation

of § 97-37-1] in _____________ [list court and details of previous conviction] on __________

[list date of previous conviction] and of __________________ [specify violation of § 97-37-1] 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 _____.