6th Cir. Pattern Crim. Jury Instr. 14.04

(1) The defendant is charged with the crime of possessing [name controlled substance]. [Name controlled substance] is a controlled substance. For you to find the defendant guilty of this crime, you must find that the government has proved each and every one of the following elements beyond a reasonable doubt:

(A) First, the defendant possessed [name controlled substance].

(B) Second, the defendant did so knowingly [or intentionally].

(2) Now I will give you more detailed instructions on some of these terms.

(A) [Insert applicable definition of possession from Instructions 2.10, 2.10A, and 2.11 here or as a separate instruction].

(B) To prove that the defendant “knowingly” possessed the [name controlled substance], the defendant does not have to know that the substance was [name controlled substance]. It is enough that the defendant knew that it was some kind of controlled substance. Further, the defendant did not have to know how much [name controlled substance] he possessed. It is enough that the defendant knew that he possessed some quantity of [name controlled substance].

(3) If you are convinced that the government has proved all of these elements, say so by returning a guilty verdict on this charge. If you have a reasonable doubt about any one of these elements, then you must find the defendant not guilty of this charge.