5th Cir. Pattern Jury Instr. (Criminal) 2.81

18 U.S.C. § 2119

Title 18, United States Code, Section 2119, makes it a crime for anyone to take [attempt to

take] a motor vehicle that has been transported in interstate [foreign] commerce from a person [the

presence of someone] by force and violence [by intimidation] with the intent to cause death or

serious bodily harm.

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 intentionally took [attempted to take] from ____________, a

person [presence of another] a motor vehicle, ______ (as described in the indictment);

Second: That the motor vehicle had been transported in interstate [foreign] commerce;

Third: That the defendant did so by means of force and violence [intimidation];

Fourth: That the defendant intended to cause death or serious bodily harm; and

Fifth: That the defendant possessed such intent when he [she] took [attempted to take] the

victim’s vehicle.

[Sixth: That serious bodily injury [death] resulted.]

[Serious bodily injury means bodily injury which involves (A) a substantial risk of death;

or (B) extreme physical pain; or (C) protracted and obvious disfigurement; or (D) protracted loss

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