6th Cir. Pattern Crim. Jury Instr. 2.02

(1) Count ___ of the indictment accuses the defendant of _______ in violation of federal law. For you to find the defendant guilty of this crime, you must be convinced that the government has proved each and every one of the following elements beyond a reasonable doubt:

(A) First, that the defendant [fully define the prohibited acts and/or results required to convict].

(B) Second, that the defendant did so [fully define the precise mental state required to convict].

[(C) Third, that [fully define any other elements required to convict].]

[(2) Insert applicable definitions of terms used here.]

(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.

[(4) Insert applicable explanations of any matters not required to convict here.]

Use Note

Definitions of the precise mental state required for various federal offenses are provided in the elements instructions in Chapters 10 et seq.

Bracketed paragraph (1)(C) should be included when the crime cannot be broken down neatly into two elements. Additional paragraphs should be added as needed to cover all the elements.

Bracketed paragraph (2) should be included when terms used in paragraphs (1)(A-C) require further explanation.

Bracketed paragraph (4) should be included when it would be helpful to explain matters that need not be proved in order to convict. When used, a final sentence should be included for balance emphasizing what it is that the government must prove to convict.