11th Cir. Pattern Jury Instr. (Criminal) O10.1

or Injury of a Person

18 U.S.C. § 248(a)(1)

It’s a Federal crime for anyone to use [force] [a threat of force] [a physical

obstruction] to intentionally [injure] [intimidate] [interfere with] a person

[obtaining] [providing] reproductive-health services.

The Defendant can be found guilty of this crime only if all the following

facts are proved beyond a reasonable doubt:

(1) the Defendant used [force] [a threat of force] [a physical

obstruction] to intentionally [injure] [intimidate] [interfere with]

the person named in the indictment; [and]

(2) the Defendant did so knowingly and because the person was or had

been [providing] [obtaining] reproductive-health services; [and]

[(3) the Defendant's acts resulted in [death] [bodily injury].]

[To “force” a person means to exert or apply physical compulsion or

restraint against the person.]

[To “interfere with” means to restrict a person's freedom of movement.]

[To “intimidate” a person means to place the person in reasonable fear of

bodily harm either to that person or to someone else.]

[To “physically obstruct” means to block the entry to or exit from a facility

that provides reproductive-health services.]

“Reproductive-health services” are medical, surgical, counseling, or referral

services relating to the human reproductive system – including services relating to

pregnancy or the termination of a pregnancy – provided in a hospital, clinic,

physician’s office, or other facility.

[A “bodily injury” means any injury to the body, no matter how temporary.

It includes any cut, abrasion, bruise, burn, or disfigurement; physical pain; illness;

or impairment of the function of a bodily member, organ, or mental faculty.]