Proposed Mississippi Plain Language Model Jury Instructions - Criminal 4508

[Name of defendant] is charged in count ___ with possessing explosives.

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 possessed [a/an] __________________________ [specify

dynamite caps; nitroglycerine caps; fuses; detonators; dynamite; nitroglycerine; explosives; gas

or stink bombs; other explosives used in committing a crime; bomb; grenade; rocket with a

propellant charge of more than four ounces; missile with an explosive charge of more than

one-quarter (1/4) ounce; mine; a combination of parts designed to convert a device into an

explosive device; a device which included a breakable container and flammable liquid or

compound and a wick which can ignite the flammable liquid or compound and can be carried or

thrown; or other explosive used in committing a crime],

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 _____.