VA · jury_instructions
Va. Model Jury Instr. Crim. No. 4.400
Abduction—By Parent, Family or Household Member, Outside the Commonwealth
The defendant is charged with the crime of abduction. The Commonwealth must prove beyond
a reasonable doubt each of the following elements of that crime:
(1) That the defendant is a [parent; family member, household member] of (name of child); and
(2) That the defendant by [force; intimidation; deception] did [seize; take; transport; detain; hide]
(name of child); and
(3) That the defendant did so with the intent [to deprive (name of child) of his personal liberty; to
withhold or conceal (name of child) from (name of person, authority, or institution legally entitled to his
charge)]; and
(4) That the defendant acted without legal justification or excuse and in violation of a court order
issued in a then pending proceeding; and
(5) That (name of child) was removed from the Commonwealth by the defendant.
If you find from the evidence that the Commonwealth has proved beyond a reasonable doubt
each of the above elements of the crime as charged, 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 any one or
more 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
3124678c8b5114ea35e824c8fbfa9eb39da515d1aaeedd7173a9250b3bdfc624
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