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TABLE OF CONTENTS

_____________


Resolution

Committee Membership

Introduction

Acknowledgments


Standard of Appellate Review for Jury Instructions Generally


General Instructions


Chapter 1.00General Principles

Instruction

1.01Introduction

1.02Jurors’ Duties

1.03Presumption of Innocence, Burden of Proof, Reasonable Doubt

1.04Evidence Defined

1.05Consideration of Evidence

1.06Direct and Circumstantial Evidence

1.07Credibility of Witnesses

1.08Number of Witnesses

1.09Lawyers’ Objections


Chapter 2.00Defining the Crime and Related Matters

2.01Introduction

2.01ASeparate Consideration - Single Defendant Charged with Multiple Crimes

2.01BSeparate Consideration - Multiple Defendants Charged with a Single Crime

2.01CSeparate Consideration - Multiple Defendants Charged with Same Crimes

2.01DSeparate Consideration - Multiple Defendants Charged with Different Crimes

2.02Definition of the Crime

2.03Definition of Lesser Offense

2.04On or About

2.05Willfully

2.06Knowingly

2.07Specific Intent

2.08Inferring Required Mental State

2.09Deliberate Ignorance

2.10Actual and Constructive Possession

2.10AActual Possession

2.11Joint Possession


Chapter 3.00Conspiracy

3.01AConspiracy to Commit an Offense--Basic Elements

3.01BConspiracy to Defraud the United States--Basic Elements

3.02Agreement

3.03Defendant’s Connection to the Conspiracy

3.04Overt Acts

3.05 Bad Purpose or Corrupt Motive

3.06 Unindicted, Unnamed or Separately Tried Co-Conspirators

3.07 Venue

3.08 Multiple Conspiracies--Material Variance From the Indictment

3.09 Multiple Conspiracies--Factors in Determining

3.10 Pinkerton Liability for Substantive Offenses Committed by Others

3.11A Withdrawal as a Defense to Conspiracy

3.11B Withdrawal as a Defense to Substantive Offenses Committed by Others

3.11C Withdrawal as a Defense to Conspiracy Based on the Statute of Limitations

3.12 Duration of a Conspiracy

3.13 Impossibility of Success

3.14 Statements by Co-Conspirators


Chapter 4.00Aiding and Abetting

4.01Aiding and Abetting

4.01ACausing an Act

4.02Accessory After the Fact


Chapter 5.00Attempts

5.01Attempt-Basic Elements

5.02Sham Controlled Substance Cases

5.03Abandonment or Renunciation


Chapter 6.00Defenses

6.01 Defense Theory

6.02 Alibi

6.03 Entrapment

6.04 Insanity

6.05 Coercion/Duress

6.06 Self-Defense

6.07 Justification

6.08Fraud – Good Faith Defense

6.09Entrapment by Estoppel


Chapter 7.00Special Evidentiary Matters

7.01Introduction

7.02ADefendant's Election Not to Testify or Present Evidence

7.02BDefendant’s Testimony

7.02CWitness Other than Defendant Invoking the Fifth Amendment

7.03 Opinion Testimony

7.03AWitness Testifying to Both Facts and Opinions

7.04Impeachment by Prior Inconsistent Statement Not Under Oath

7.05AImpeachment of Defendant by Prior Conviction

7.05BImpeachment of a Witness Other Than Defendant by Prior Conviction

7.06ATestimony of a Paid Informant

7.06BTestimony of an Addict-Informant Under Grant of Immunity or Reduced Criminal Liability

7.07 Testimony of a Witness Under Grant of Immunity or Reduced Criminal Liability

7.08Testimony of an Accomplice

7.09Character and Reputation of Defendant

7.10Age of Witness

7.11Identification Testimony

7.12Summaries and Other Materials Not Admitted in Evidence

7.12ASecondary-Evidence Summaries Admitted in Evidence

7.13 Other Acts of Defendant

7.14 Flight, Concealment of Evidence, False Exculpatory Statements

7.15 Silence in the Face of Accusation [withdrawn]

7.16 Possession of Recently Stolen Property

7.17 Transcriptions of Tape Recordings

7.18 Separate Consideration--Evidence Admitted Against Certain Defendants Only

7.19 Judicial Notice


Chapter 8.00Deliberation and Verdict

8.01 Introduction

8.02 Experiments, Research and Investigation

8.03Unanimous Verdict

8.03A Unanimity of Theory [withdrawn]

8.03BUnanimity Not Required – Means

8.03CUnanimity Required – Statutory Maximum Penalty Increased, Controlled Substances

8.04 Duty to Deliberate

8.05 Punishment

8.06 Verdict Form

8.07Lesser Offense, Order of Deliberations, Verdict Form

8.08 Verdict Limited to Charges Against This Defendant

8.09 Court Has No Opinion

8.10 Juror Notes


Chapter 9.00Supplemental Instructions

9.01 Supplemental Instructions in Response to Juror Questions

9.02 Rereading of Testimony

9.03 Partial Verdicts

9.04 Deadlocked Jury

9.05Questionable Unanimity After Polling



Elements Instructions


Chapter 10.00 Fraud Offenses

10.01Mail Fraud (18 U.S.C. § 1341)

10.02Wire Fraud (18 U.S.C. § 1343)

10.03Bank Fraud (18 U.S.C. § 1344)

10.04Fraud – Good Faith Defense


Chapter 11.00 Money Laundering Offenses

11.01 Money Laundering – Domestic Financial Transaction (18 U.S.C. § 1956(a)(1)(A) (intent to promote the carrying on of specified unlawful activity))

11.02 Money Laundering – Domestic Financial Transaction (18 U.S.C. § 1956(a)(1)(B) (knowing the transaction is designed to conceal facts related to proceeds))

11.03Money Laundering – International Transportation (18 U.S.C. § 1956(a)(2)(A) (intent to promote the carrying on of specified unlawful activity))

11.04Money Laundering – International Transportation (18 U.S.C. § 1956(a)(2)(B) (knowing that the transportation involves proceeds of some form of unlawful activity and that it is designed to conceal facts related to proceeds))

11.05Money Laundering – Undercover Investigation (18 U.S.C. § 1956(a)(3))

11.06Money Laundering – Engaging in Monetary Transactions in Property Derived from Specified Unlawful Activity (18 U.S.C. § 1957)


Chapter 12.00 Firearms Offenses

12.01Firearms – Possession of Firearm by Convicted Felon (18 U.S.C. § 922(g)(1))

12.02Firearms – Using or Carrying a Firearm During and in Relation to a Crime of Violence or Drug Trafficking Crime (18 U.S.C. § 924(c)(1)(A)(i))

12.03Firearms – Possessing a Firearm in Furtherance of a Crime of Violence or Drug Trafficking Crime (18 U.S.C. § 924(c)(1)(A)(i))


Chapter 13.00 False Statements to the United States Government

13.01Concealing a Material Fact in a Matter within the Jurisdiction of the United States Government (18 U.S.C. § 1001(a)(1))

13.02Making a False Statement in a Matter within the Jurisdiction of the United States Government (18 U.S.C. § 1001(a)(2))

13.03Making or Using a False Writing in a Matter within the Jurisdiction of the United States Government (18 U.S.C. § 1001(a)(3))


Appendix

18 U.S.C. § 1956 Laundering of monetary instruments – diagrams of offense