US-CA9 · jury_instructions
9th Cir. Model Jury Instr. (Criminal) 17.5
Attempted Kidnapping—Foreign Official or Official Guest (18 U.S.C. § 1201(d))
The defendant is charged in [Count _______ of] the indictment with attempting to kidnap [a foreign official] [an official guest] [an internationally protected person] in violation of Section 1201(d) of Title 18 of the United States Code. For the defendant to be found guilty of that charge, the government must prove each of the following elements beyond a reasonable doubt:
First, the defendant intended to [seize] [confine] [inveigle] [decoy] [kidnap] [abduct] [carry away] and hold [a foreign official] [an official guest] [an internationally protected person] against [his] [her] will; and
Second, the defendant did something that was a substantial step toward committing the crime.
A “substantial step” is conduct that strongly corroborated the defendant’s intent to commit the crime. To constitute a substantial step, a defendant’s act or actions must unequivocally demonstrate that the crime will take place unless interrupted by independent circumstances. Mere preparation is not a substantial step toward committing the crime.
Jurors do not need to agree unanimously as to which particular act or actions constituted a substantial step toward the commission of a crime.
To “kidnap” a person means to unlawfully hold, keep, detain, or confine the person
against their will and without their consent. Involuntariness or coercion in connection with the
victim’s detention is an essential part of the offense.
[To “inveigle” a person means to lure, entice or lead the person astray by false representations, promises, or other deceitful means.]
Provenance
- Source
- ce9.uscourts.gov
- Retrieved
- 2026-08-20
- Edition
- 2026-08-20
- Content hash
9fb58e385570e96ad0e9cd558da788916ee2a636e7c27f169cd005b1a8fcbc64
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