N.C.P.I.—Crim. 271.92

The defendant has been charged with failing to have financial

responsibility while [operating (a) motor vehicle] [permitting the

operation of a motor vehicle in this State].

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

prove three things beyond a reasonable doubt:

First, that the defendant was the owner of a motor vehicle;

Second, that the defendant registered1 this motor vehicle with the

North Carolina Division of Motor Vehicles;

And Third, that the defendant [operated this motor vehicle]

[permitted this motor vehicle to be operated] in North Carolina at a time

when the defendant did not have in place the financial responsibility, that

is liability insurance in the amount of (insert amount) as required by

North Carolina law.2

(If you find from the evidence that the owner of a motor vehicle

registered or required to be registered in this State [operated this

vehicle] [permitted this motor vehicle to be operated] in North Carolina,

and if records from the Division of Motor Vehicles indicate that the owner

did not have the required financial responsibility, you may, but are not

compelled to, find that the owner [operated] [permitted the operation of]

a motor vehicle without the required financial responsibility).3

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

about the alleged date the defendant was the owner of a motor vehicle,

that the defendant registered this motor vehicle with the North Carolina

Division of Motor Vehicles, that the defendant [operated this motor

vehicle] [permitted this motor vehicle to be operated] in North Carolina at

a time when the defendant did not have in place the financial

responsibility, that is liability insurance in the amount of (insert amount)

as required by North Carolina law, 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.