VA · jury_instructions
Va. Model Jury Instr. Crim. No. 42.180
Escape—Work Release (Jail Inmate)
The defendant is charged with the crime of failing to comply with the conditions of work
release. The Commonwealth must prove beyond a reasonable doubt each of the following elements
of that crime:
(1) That the defendant was a prisoner sentenced to confinement in jail; and
(2) That the defendant, without proper authority and without just cause, [left the area in which he
had been assigned to work; left the area in which he had been assigned to attend an educational or other
rehabilitative program; left the vehicle or route involved in his going to or coming from the place to
which he had been assigned for educational or other rehabilitative purposes or to work]; and
(3) That the defendant left the Commonwealth.
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 of
failing to comply with the conditions of work release (felony) [but you shall not fix the punishment
until your verdict has been returned and further evidence has been heard by you].
If you find from the evidence that the Commonwealth has proved beyond a reasonable doubt
each of the first two elements of the crime as charged, but that the Commonwealth has failed to
prove beyond a reasonable doubt the third element, then you shall find the defendant guilty of
failing to comply with the conditions of work release (misdemeanor) [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
element (1) or element (2) above, or both, 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
42c349d1d829ed026251c8b8b6fdc2071a3eb1a7705a6c25fe633d209a9dddf1
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