VA · jury_instructions
Va. Model Jury Instr. Crim. No. 12.400
Possession of Burglary Tools
The defendant is charged with the crime of possession of burglary [tools; implements; outfit] with
intent to commit [burglary; robbery; larceny]. The Commonwealth must prove beyond a reasonable
doubt each of the following elements of that crime:
(1) That the defendant had in his possession any [tools; implements; outfit] which might be used for
purposes of [burglary; robbery; larceny]; and
(2) That he intended to use [these tools; these implements; this outfit] to commit [burglary; robbery;
larceny].
If you find from the evidence that the Commonwealth has proved beyond a reasonable doubt
each of the above elements of the crime, then you shall find the defendant guilty [but you shall not
fix the punishment until your verdict has been returned and further evidence has been heard by
you].
If you find that the Commonwealth has failed to prove beyond a reasonable doubt either or
both of the elements of the crime, then you shall find the defendant not guilty.
History
Virginia Model Jury Instructions – Criminal, Release 26, October 2025. The unannotated set, posted by the Supreme Court of Virginia at vacourts.gov; the book states that it is made available with the permission of the publisher, Matthew Bender & Company, Inc.
Provenance
- Source
- vacourts.gov
- Retrieved
- 2026-10-11
- Edition
- crim-2025-10-01
- Content hash
98febe924090df1ea16c35687805d668d75083cc7e74a28b25ab0d4a391c2f6c
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