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Criminal Jury Instructions

Using these Instructions

Bold-faced titles and subheadings are included to make the instructions easier to read and are not part of the instruction.

Angle brackets and italicized text are used to enclose directives to follow in customizing the charge. E.g., <insert name of person injured>. Angle brackets are also used to refer to other instructions that may contain some additional useful information. E.g., <See Affirmative Defense, Instruction 2.9-1.>. 

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Using these Instructions

Alternative Choices
Parentheses are used to indicate that a choice between words or phrases is necessary. This is most commonly used for gender-specific pronouns, e.g., (he/she) or (his/her). It is also used when a statute offers several terms, not all of which may be applicable to the charged offense. If a statute has choices that are lengthy, such that stringing them together in a single parentheses would be cumbersome to read, they are separated into a bulleted list. For example, 

a person is guilty of kidnapping in the first degree when (he/she) abducts another person and (his/her) intent is to compel a third person <insert as appropriate:>

  • to pay or deliver money or property as ransom.

  • to engage in particular conduct or to refrain from engaging in particular conduct.

Optional Language
Square brackets are used to indicate that a portion of the instruction is optional. It will be preceded by an italicized directive defining the circumstances under which the language would be appropriate, unless it is clear from the language itself. For example,

[<If the defendant has testified about (his/her) intent:> In this case, the defendant has testified as to (his/her) intent. You should consider my earlier instruction on evaluating the defendant's testimony as you would any other witness.]

Note that square brackets in commentary have their common meaning, i.e., the paraphrasing of small portions of quoted material.

Definitions of Terms
Terms that are defined by statute or case law are hyperlinked to the glossary.


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