N.C.P.I.—Crim. 236A.33

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

prove three things beyond a reasonable doubt.

First, that the defendant:

a) displayed a visual image within 500 feet of a [funeral]

[memorial service] [family processional to the [funeral]

[memorial service]] that conveyed [fighting words] [[actual

threats of harm] [imminent threats of harm]] directed to a

[person] [property] associated with the [funeral] [memorial

service] [family processional to the [funeral] [memorial

service]];1

b) uttered within 500 feet of a [funeral] [memorial service]

[family processional to the [funeral] [memorial service]]

[[loud] [threatening] [abusive language]] [[singing] [chanting]

[whistling] [yelling]]2 in a manner that would tend to

[impede] [disrupt] [disturb] [interfere] with a [funeral]

[memorial service] [family processional to the [funeral]

[memorial service]];

c) [[attempted3 to block] [blocked]] [pedestrian] [vehicular]

access to the [ceremonial site] [location being used] for a

[funeral] [memorial service] [family processional to the

[funeral] [memorial service]],

Second, that the defendant’s conduct occurred [within two hours

[before] [after]] [during] the [funeral] [memorial service] [family

processional to the [funeral] [memorial service]];

And Third, that the defendant intentionally engaged in this conduct

to [impede] [disrupt] [disturb] [interfere with] the orderly administration

of a [funeral] [memorial service] [family processional to the [funeral]

[memorial service]].

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

about the alleged date the defendant intentionally:

a) displayed a visual image within 500 feet of a [funeral]

[memorial service] [family processional to the [funeral]

[memorial service]] that conveyed [fighting words] [[actual

threats of harm] [imminent threats of harm]] directed to a

[person] [property] associated with the [funeral] [memorial

service] [family processional to the [funeral] [memorial

service]];

b) uttered within 500 feet of a [funeral] [memorial service]

[family processional to the [funeral] [memorial service]]

[[loud] [threatening] [abusive language]] [[singing] [chanting]

[whistling] [yelling]] [with noise amplification] [without noise

amplification] in a manner that would tend to [impede]

[disrupt] [interfere] with a [funeral] [memorial service] [family

processional to the [funeral] [memorial service]];

c) [[attempted to block] [blocked]] [pedestrian] [vehicular]

access to the [ceremonial site] [location being used] for a

[funeral] [memorial service] [ceremonial site] [location being

used] for a [funeral] [memorial service] [family processional

to the [funeral] [memorial service]],

[within two hours [before] [after]] [during] the [funeral] [memorial

service] [family processional to the [funeral] [memorial service]] with the

intent to [impede] [disrupt] [disturb] [interfere with] the orderly

administration of a [funeral] [memorial service] [family processional], 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, then it would

be your duty to return a verdict of not guilty.