N.C.P.I.—Crim. 215.45

For you to find the defendant guilty of this offense the State must

prove four things beyond a reasonable doubt:

First, that the defendant [set fire to 1] [burned] [caused to be

burned] [aided, counseled, or procured the burning of] any [goods]

[wares] [merchandise] [(describe other chattels or personal property of

any kind)].

Second, that the burning occurred in a place that was not a

commercial structure. A commercial structure is any building or structure

that is designed principally for the manufacture, distribution, or exchange

of goods or services, or for any other business or trade purpose.2

Third, that the defendant did so wantonly and willfully, that is,

intentionally and without justification or excuse, with the knowledge or

reasonable grounds to believe the defendant’s act would endanger the

rights or safety of others.3

And Fourth, that the defendant did so with the intent to injure or

prejudice [the insurer] [a creditor] [the owner] [another person].4 (This

intent may be inferred from [the nature of the act] [the manner in which

the act was done] [the conduct of the parties]).5

If you find from the evidence beyond a reasonable doubt that on or

about the alleged date the defendant wantonly and willfully [set fire to]

[burned] [caused to be burned] [aided, counseled, or procured the burning

of] any [goods] [wares] [merchandise] [(describe other chattels or

personal property of any kind)], that the burning occurred in a place that

was not a commercial structure, and that the defendant had the intent to

injure or prejudice [the insurer] [the creditor] [the owner] [another

person], it would be your duty to return a verdict of guilty. If you do not

so find, or have a reasonable doubt as to one or more of these things, it

would be your duty to return a verdict of not guilty.