US-CA9 · jury_instructions
9th Cir. Model Jury Instr. (Criminal) 7.4
Alien—Encouraging Illegal Entry
8 U.S.C. § 1324(a)(1)(A)(iv))
The defendant is charged in [Count _______ of] the indictment with encouraging illegal entry by an alien in violation of Section 1324(a)(1)(A)(iv) of Title 8 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, [name of alien] was an alien;
Second, the defendant encouraged or induced [name of alien] to [come to] [enter] [reside in] the United States in violation of law; and
Third, the defendant [knew] [acted in reckless disregard of the fact] that [name of alien]’s [coming to] [entry into] [residence in] the United States would be in violation of the law.
An alien is a person who is not a natural-born or naturalized citizen of the United States. An alien enters the United States in violation of law if not duly admitted by an Immigration Officer.
For purposes of this statute, the term “encourage or induce” means the intentional encouragement of an unlawful act or the provision of assistance to a wrongdoer with the intent to further the commission of an offense.
Provenance
- Source
- ce9.uscourts.gov
- Retrieved
- 2026-08-20
- Edition
- 2026-08-20
- Content hash
4926ad08ff7e56b61bb6914cf46e46aeb8bc4de4844eb427583ea453b05bdffe
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