11th Cir. Pattern Jury Instr. (Criminal) O61

18 U.S.C. § 1546(a) (First Paragraph)

It’s a Federal crime to knowingly [possess] [use] a false or counterfeit visa

or other document required [for entry into] [as evidence of an authorized stay or

employment in] 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 Defendant knowingly [possessed] [used] [tried to use] a[n]

[immigrant or nonimmigrant visa] [permit] [border -crossing card]

[alien-registration receipt card] required [for entry into] [as

evidence of an authorized stay or employment in] the United

States, as charged; [and]

(2) The Defendant knew that the [immigrant or nonimmigrant visa]

[permit] [border-crossing card] [alien -registration receipt card]

[other document] [had been forged, counterfeited, altered, or

falsely made] [had been procured by means of a false claim or

statement][.] [; and]

[(3) intended to [help an act of international terrorism] [help commit a

drug-trafficking crime].]

A “false document required to enter or stay in the United States” is an

immigrant or nonimmigrant visa, permit, border -crossing card, or alien -

registration receipt card – required for entry into or as evidence of an authorized

stay or employment in the United States – that has been forged, counterfeited,

altered, or falsely made.

To “use” a document is to show it to someone else.

[An “act of international terrorism” means a criminal act that’s dangerous to

human life and apparently intended to intimidate or coerce a civilian population,

influence the policy of a government by intimidation or coercion, or affect the

conduct of a government by assassination or kidnapping. The act must occur

outside the United States or transcend national boundaries and affect the United

States because of the way it’s carried out, the people targeted, or the place where

the perpetrator operates or seeks asylum.]

[A “drug-trafficking crime” means any felony punishable under the

Controlled Substances Act, 21 U.S.C. § 801 et seq.]