11th Cir. Pattern Jury Instr. (Criminal) O45.2

18 U.S.C. § 1111

It’s a Federal crime to murder another person while [committing]

[attempting to commit] the crime of [arson] [escape] [murder] [kidnapping]

[treason] [espionage] [sabotage] [aggravated sexual abuse] [sexual abuse] [child

abuse] [burglary] [robbery] within the [special maritime] [territorial] jurisdiction of

the United States.

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

facts are proved beyond a reasonable doubt:

(1) the victim, [victim’s name], was killed;

(2) the death of the victim occurred as a result of the Defendant’s

knowingly [committing] [attempting to commit] the crime

specified in the indictment; and

(3) the killing took place within the [special maritime] [territorial]

jurisdiction of the United States.

The crime is “felony murder” – a killing that takes place during the knowing

and willful commission of some other specified felony crime.

The Government does not have to prove that the Defendant had a

premeditated plan or intent to kill the victim. The Government only has to prove

beyond a reasonable doubt that the Defendant knowingly [committed] [attempted

to commit] the crime specified and that the victim died during and as a result of

that crime.

If you find beyond a reasonable doubt that the crime occurred at the location

described in the indictment, that location is within the [special maritime]

[territorial] jurisdiction of the United States.