Mont. Crim. Jury Instr. 5-121(a) (2022)

To convict the Defendant of aggravated kidnapping, the State must prove the following elements:

1. That the Defendant restrained _________________________ by [secreting or holding him/her in a place of isolation] [using or threatening to use physical force];

AND

2. That the Defendant restrained _________________________ with the purpose to [hold for ransom or reward] [hold as a shield or hostage] [facilitate the commission of (any felony)] [facilitate the flight after the commission of (any felony)] [inflict bodily injury on _______________________] [inflict bodily injury on another] [terrorize _________________________] [terrorize another] [interfere with the performance of any (governmental) (political) function] [hold another in a condition of involuntary servitude];

AND

3. That in so doing the Defendant acted without lawful authority;

AND

4. That the Defendant acted knowingly or purposely.

If you find from your consideration of the evidence that all of these elements have been proved beyond a reasonable doubt, then you should find the Defendant guilty.

If, on the other hand, you find from your consideration of the evidence that any of these elements has not been proved beyond a reasonable doubt then you should find the Defendant not guilty.