VA · jury_instructions
Va. Model Jury Instr. Crim. No. 4.600
Violation of Custody/Visitation Order Outside the Commonwealth
The defendant is charged with the crime of withholding a child from the child’s parent or legal
guardian in violation of a court order. The Commonwealth must prove beyond a reasonable doubt
each of the following elements of that crime:
(1) That the defendant withheld (name of child) from (name of parent or legal guardian); and
(2) That the defendant did so knowingly, wrongfully and intentionally; and
(3) That the defendant did so in a clear and significant violation of a court order respecting the
custody or visitation of such child; and
(4) That (name of child) was withheld outside of 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
bb3ecd99d50eca84b3e8351950b785d4c03c480d17e69540dac9a71b700654bc
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