Mont. Crim. Jury Instr. 7-106(a) (2022)

To convict the Defendant of the charge of tampering with public records or information, the State must prove the following elements:

1. That the Defendant made a [false entry in] [false alteration of] a [record] [document] [legislative bill or enactment] [thing];

AND

2. That the [record] [document] [legislative bill or enactment] [thing] [(belonged to the government) (was received by the government) (was issued by the government) (was kept by the government) and (was used for information or record) (was required by law to be kept by others for information of the government)];

AND

3. That the Defendant acted knowingly.

OR

1. That the Defendant [made] [presented] [used] a [record] [document] [thing];

AND

2. That the Defendant knew it to be false;

AND

3. That the Defendant had the purpose that it be taken as a genuine part of information or records [(belonging to) (received by) (issued by) (kept by) the government] [required by law to be kept by others for information of the government].

OR

1. That the Defendant [destroyed] [concealed] [removed] [impaired the truthfulness or availability of] a [record] [document] [thing];

AND

2. That the Defendant acted purposely.

OR

1. That the Defendant misrepresented the Defendant's identity [the use for which personal information is sought] in order to obtain personal information from a motor vehicle record under MCA �� 61-11-507, 61-11-508, or 61-11-509.

AND

2. That the Defendant acted purposely or knowingly.

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.