5th Cir. Pattern Jury Instr. (Criminal) 2.11

18 U.S.C. § 241

Title 18, United States Code, Section 241, makes it a crime for two or more persons to

conspire to injure [oppress] [threaten] [intimidate] any person in the free exercise or enjoyment of

any right or privilege secured to the person by the Constitution or laws of the United States.

For you to find the defendant guilty of this crime, you must be convinced that the

government has proved each of the following beyond a reasonable doubt:

First: That the defendant entered into a conspiracy to injure [oppress] [threaten]

[intimidate] one or more persons;

Second: That the defendant specifically intended by the conspiracy to hinder [prevent]

[interfere with] ___________________’ s ( name victim ) enjoyment of a right secured by the

Constitution or laws of the United States; and

Third: That bodily injury resulted from the defendant’s conduct.

[Third: That the defendant’s conduct included the use [attempted use] [threatened use] of

a dangerous weapon [explosive].]

[Third: That ___________________ ( name victim) died as a result of acts committed in

furtherance of the conspiracy. The government need not prove that the defendant intended for the

person to die. It must prove that the person’ s death was a foreseeable result of the defendant ’s

conduct.]

[Third: That the defendant ’s conduct included kidnapping [an attempt to kidnap]

[aggravated sexual abuse] [an attempt to commit aggravated sexual abuse] [an attempt to kill].]

The indictment charges that the defendant conspired to deprive __________________

(name victim) of the following right: ___________________ ( describe, e.g., right to travel, to

vote, to enjoy equal access to public accommodations ). You are instructed that this right is one

secured by the Constitution and laws of the United States.