VA · jury_instructions
Va. Model Jury Instr. Crim. No. 45.110
Reckless Driving—On Suspended or Revoked License—Causing Death of Another
Guilt Phase:
The defendant is charged with the crime of reckless driving on a [suspended; revoked] license,
causing the death of another. The Commonwealth must prove beyond a reasonable doubt each of
the following elements of that crime:
(1) That the defendant was driving a vehicle on a highway;
(2) That he [was driving in a manner so as to endanger the life, limb, or property of any person; name
action prohibited by Va. Code Ann. § 46.2-853 to § 46.2-865];
(3) That he was driving without a valid operator’s license due to a [suspension; revocation] for a
moving violation; and
(4) That his reckless driving was the sole and proximate cause of the death of another.
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
reckless driving on a [suspended; revoked] license causing the death of another, [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
elements (1) and (2) of the above elements of the crime charged, but has not proved beyond a
reasonable doubt either or both of elements (3) and (4), then you shall find the defendant guilty of
reckless driving, [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
elements (1) and (2) of the crime charged, but has not proved beyond a reasonable doubt either or
both of elements (3) and (4), and that the defendant’s culpability was slight, then you may find the
defendant guilty of improper driving.
If you find that the Commonwealth has failed to prove beyond a reasonable doubt either or
both of elements (1) and (2) 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
46c9480a09f373064f8179153f54f9bffccdbfebecb051169f3aaeaf873047b8
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