5th Cir. Pattern Jury Instr. (Criminal) 2.36C

18 U.S.C. §§ 842(d), 844(a)(1)

Title 18, United States Code, Sections 842(d) and 844(a)(1), make it a crime for a person

to knowingly distribute explosive materials to [a person in the prohibited category, e.g., a

convicted felon] when the distributor knows that such a person is [a member of a prohibited

category, e.g., a convicted felon].

____________ (name explosive material) is an explosive material within the meaning of

this law.

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 knowingly distributed an explosive material as named in the

indictment to ____________ (name of person receiving the explosive material);

Second: That at the time of the distribution to ____________ ( name of person receiving

the explosive material), he [she] was ____________ ( identify prohibited category into which the

person falls; e.g., a convicted felon); and

Third: That at the time of the distribution, the defendant knew that ____________ ( name

of the person receiving the explosive material ) was ____________ ( identify prohibited category

into which the person falls; e.g., a convicted felon).

To “distribute” something simply means to deliver or transfer possession of it to someone

else, with or without any financial interest in the transaction.