These are form jury instructions on assorted topics, courtesy of Larry Novins. WARNING: The items in this collection are drawn from a variety of sources over a period of years, and we haven't attempted to screen or update anything. No warranty, express or implied, as to their current accuracy, appropriateness in any particular case, or anything else!

We'd like other lawyers' work in this area as well. If you have have similar material which you're willing to see posted here, please contact Greg King (greg.king@state.vt.us)

A note from Larry Novins: During the last few years I have attempted to collect jury instructions. These instructions, many of which are still in draft form, were obtained from instructions used in our Courts, jury instruction books, miscellaneous instructions given to me by other people, and instructions I have drafted while reading some court opinions. Many of these instructions were dictated, and remain as "drafts." I have not even proof read some of them. They are a work-in-progress. Some of the instructions may be out-dated or in need of revision. I do hope that they provide a good starting point for anyone who needs them.

ABANDONMENT OF CRIMINAL ENTERPRISE
ABANDONMENT OF CRIMINAL ENTERPRISE
ABSENCE OF WITNESS
ACCESSORY AFTER THE FACT
ACCOMPLICE LIABILITY - AIDING AND ABETTING UNLAWFUL DELIVERY OF MARIJUANA
ACCOMPLICE - INFORMER - IMMUNITY
ACCOMPLICE LIABILITY AIDING AND ABETTING
ACCOMPLICE LIABILITY
ACCOMPLICE-VERSION II
ACTING UNDER THE INFLUENCE OF DRUGS OR ALCOHOL - EXPLAINED 19.05
ACTION ON THE ADVICE OF COUNSEL - EXPLAINED
ACTUAL KNOWLEDGE
ACTUAL PHYSICAL CONTROL OF A VEHICLE
AFFECT OF DEFENDANT'S FAILURE TO TESTIFY
AFFIRMATIVE DEFENSE OF MENTAL DISEASE OR DEFECT
AFFIRMATIVE DEFENSE OF MENTAL DISEASE OR DEFECT
aggravated assault - lesser included offenses
AGGRAVATED SEXUAL ASSAULT
AGGRAVATED ASSAULT-13 V.S.A. 1024(a)(2)
AGGRAVATED ASSAULT - ACTING RECKLESSLY
AIDING AND ABETTING - EXPLAINED
ALIBI - EXPLAINED
ALIBI
ANNOUNCING VERDICT
ASSAULT AND ROBBERY - 13 V.S.A.608
ASSAULT & ROBBERY -- 13 V.S.A. 608(a)
ASSAULT AND ROBBERY -- 13 V.S.A. 608(b)-- with a dangerous weapon
ATTEMPT - A SUBSTANTIAL STEP
ATTEMPTED FALSE PRETENSES
ATTEMPTED AGGRAVATED ASSAULT-13 V.S.A.1024(A)(1)
ATTEMPTED SIMPLE ASSAULT - 13 V.S.A.1023(a)(1)
BODILY INJURY
BREATH TEST ADMINISTERED BEFORE JULY 1, 1991
BURDEN OF PROOF
BURDEN OF PROOF: SELF DEFENSE
BURDEN OF PROOF: SELF DEFENSE
BURDEN OF PROOF
BURGLARY - 13 V.S.A. 1201(a) - ESSENTIAL ELEMENTS AND DEFINITIONS
BURGLARY
BURGLARY
BUSHEY INSTRUCTION
CARELESS AND NEGLIGENT DRIVING - 23 V.S.A. 10919(a)
CARELESS AND NEGLIGENT OPERATION
CAUSATION
CHARACTER EVIDENCE - REPUTATION OF THE DEFENDANT
CHILDREN'S TESTIMONY IN GENERAL
CHILDREN'S TESTIMONY IN GENERAL
CIRCUMSTANCES MANIFESTING AN EXTREME INDIFFERENCE TO THE VALUE OF HUMAN LIFE
CIRCUMSTANCES MANIFESTING AN EXTREME INDIFFERENCE TO THE VALUE OF HUMAN LIFE
CIRCUMSTANTIAL EVIDENCE
CLEARY - FINAL JURY INSTRUCTIONS (cleary.inst)
CO-DEFENDANT'S TESTMONY
COERCION OR DURESS - EXPLAINED
Coersion
COMMON SCHEME OR PLAN - EVIDENCE OF ACTS OR DECLARATIONS OF CONFEDERATES
CONFESSION - STATEMENT- VOLUNTARINESS (MULTIPLE DEFENDANTS)
CONJECTURE
Consider Each Charge Separately
CONSIDER ONLY THE OFFENSE CHARGED
CONSTRUCTIVE POSSESSION
CORPORAL PUNISHMENT
CREDIBILITY OF WITNESSES: THE DEFENDANT'S CONVICTION OF A FELONY
CREDIBILITY OF WITNESSES: THE DEFENDANT'S CONVICTION OF A FELONY
CREDIBILITY OF WITNESS: THE REFUSAL OF A WITNESS OR DEFENDANT TO ANSWER
CREDIBILITY OF WITNESSES: THE DEFENDANT AS A WITNESS
CREDIBILITY OF WITNESSES
CREDIBILITY OF POLICE OFFICERS
CREDIBILITY OF A WITNESS: PERJURER
CREDIBILITY OF WITNESS' - ACCOMPLICE
CREDIBILITY OF WITNESSES - DRUG OR ALCOHOL ABUSER
CREDIBILITY OF WITNESSES - INCONSISTENT STATEMENT (FALSUS IN UNO FALSUS IN OMNIBUS)
CREDIBILITY OF WITNESSES - CONVICTION OF FELONY
CREDIBILITY OF WITNESSES - BAD REPUTATION FOR TRUTH
CREDIBILITY OF WITNESSES
CROSS EXAMINATION OF DEFENDANT'S CHARACTER WITNESS
CULTIVATION OF MARIJUANA-18 V.S.A.4230(a)(2)
D.W.I.: 23 V.S.A. 1201(a)(2)
D.W.I. DEATH RESULTING - 23 V.S.A. 1210(e)
DEATH: CAUSATION
DEFENDANT'S STATEMENT
DEFENDANT'S CONFESSION
DEFENSE OF PROPERTY
DEFENSE OF PROPERTY
DEFENSE OF A THIRD PERSON
DELIBERATE IGNORANCE - EXPLAINED
DELIVERING COCAINE - 18 V.S.A. 4231
DIMINISHED CAPACITY
DIMINISHED CAPACITY
DRAM SHOP LIABILITY
DURESS
DURESS
DWI: SUBSEQUENT OFFENSE
EIGHTY-SEVEN
EMERGENCY - DANGER
ENTRAPMENT - EXPLAINED
ENTRAPMENT
ENTRAPMENT
ENTRAPMENT
ENTRAPMENT
ESSENTIAL ELEMENTS
ESSENTIAL ELEMENTS - AGGRAVATED ASSAULT and SIMPLE ASSAULT
EVIDENCE OF FLIGHT BY DEFENDANT
EVIDENCE OF FLIGHT BY DEFENDANT
EVIDENCE OF INTOXICATION
EVIDENCE OF FLIGHT
EVIDENCE OF INTOXICATION
EVIDENCE ADMITTED FOR A LIMITED PURPOSE ONLY
EXPERT WITNESS
EXPERT TESTIMONY
EXPERT WITNESSES
EYEWITNESS IDENTIFICATION OF THE DEFENDANT
EYEWITNESS IDENTIFICATION OF THE DEFENDANT
FALSE - DEFINED
FALSE - DEFINED
FALSE PRETENSES - 13 V.S.A. 2002
FALSE EXCULPATORY STATEMENTS
FALSE ALARM - 13 V.S.A. 1751(a)
FALSE ALARM - 13 V.S.A. 1751(a)
Family or household members
Felony murder
FELONY POSSESSION OF MARIJUANA-18 V.S.A.4230(a)(2)
FINGERPRINTS OR HANDWRITING EVIDENCE
FIRST DEGREE MURDER
FOUR DUTIES IN DELIBERATIONS
FRAUDULENT NONDISCLOSURE
GENERAL GUIDES TO DELIBERATIONS
GROSS NEGLIGENCE
GROSS NEGLIGENT OPERATION
HARASSMENT
Holding on objections
IMMEDIATE FLIGHT OR CONCEALMENT
IMPEDING AN OFFICER 13 V.S.A. 3001
INFERENCE AFTER JULY 1, 1991; SECTION 1204(a)(4)
INFORMATION OR INDICTMENT - CHARGE
INFORMATION NOT EVIDENCE
INFORMATION, EFFECT OF
INFORMATION NOT EVIDENCE
INFORMER TESTIMONY
INSANITY DEFENSE - 13 V.S.A. 4801
INSANITY DEFENSE - 13 V.S.A. 4801
INSTRUCTIONS TO BE CONSIDERED AS A WHOLE
INSTRUCTIONS TO BE CONSIDERED AS A WHOLE
INTOXICATING LIQUOR - DEFINITION
INTRODUCTION: GENERAL RESPONSIBILITIES OF JURORS089.TXT
INVOLUNTARY MANSLAUGHTER
INVOLUNTARY MANSLAUGHTER BY OMISSION OF LEGAL DUTY
INVOLUNTARY MANSLAUGHTER
JUSTIFIABLE HOMICIDE 13 V.S.A.  2305
Kidnapping
KNOWLEDGE OR INTENT
LESSOR INCLUDED OFFENSE
LEWD AND LASCIVIOUS CONDUCT WITH A CHILD
LEWD AND LASCIVIOUS CONDUCT 13 V.S.A. 2602
LEWD AND LASCIVIOUS CONDUCT
LEWD AND LASCIVIOUS CONDUCT WITH A CHILD
LEWD AND LASCIVIOUS CONDUCT WITH CHILD
LEWD AND LASCIVIOUS CONDUCT 13 V.S.A. 2601
LEWD AND LASCIVIOUS CONDUCT WITH CHILD; LEWDNESS
LIMITING INSTRUCTIONS
LITTERING - 24 V.S.A. 2201(A)
SIMPLE ASSAULT: MUTUAL CONSENT
MERE PRESENCE - DEFINED
MERE PRESENCE
MISDEMEANOR POSSESSION OF MARIJUANA-18 V.S.A.4230(a)(1)
MITIGATION OF SIMPLE ASSAULT-MUTUAL CONSENT
MOTIVE: HOMICIDE
MOTIVE - EXPLAINED
MURDER, MANSLAUGHTER, VARIOUS LESSER INCUDEDS
MURDER BY POISON OR BY LYING IN WAIT
NECESSITY DEFENSE
NECESSITY DEFENSE
NUMBER OF WITNESSES CALLED IS NOT CONTROLLING
NUMBER NINETY-SIX
OBSTRUCTING JUSTICE
OBSTRUCTING JUSTICE
OPERATION
PERMISSIVE INFERENCES - 23 V.S.A. 1204
PETIT LARCENY
Physical Injury
POSSESSING FIREWORKS-20 V.S.A. 3132(A)
POSSESSION OF COCAINE - 18 V.S.A.4231(a)(1)
POSSESSION OF RECENTLY STOLEN PROPERTY - INFERENCES
PRESUMPTION OF INNOCENCE
PRESUMPTION OF INNOCENCE BETWEEN DEGREES SIMPLE V. AGGRAVATED ASSAULT
PRESUMPTION OF INNOCENCE
PRESUMPTION OF INNOCENCE
PRESUMPTION OF INNOCENCE
PRESUMPTION OF INNOCENCE BETWEEN DEGREES
PRIOR CONDUCT - SEXUAL ASSAULT
PRIOR BAD ACTS
PRIOR CONDUCT
PRIOR BAD ACTS
PROOF OF KNOWLEDGE OR INTENT
PROOF OF KNOWLEDGE OR INTENT - RULE 404(b) EVIDENCE
PUBLIC HIGHWAY
RACIAL STEREOTYPES
REASONABLE DOUBT - VERSION 2
REASONABLE DOUBT
REASONABLE DOUBT - VERSION 1
REASONABLE DOUBT
REASONABLE DOUBT
REASONABLE DOUBT - VERSION 3
RECKLESS DEFINED
RECKLESS ENDANGERMENT - 13 V.S.A. 1025
RECKLESSLY DEFINED
RECKLESSLY
RECOLLECTION OF EVIDENCE
RECONCILING TESTIMONY
REGULATED DRUG OFFENSE
RESCUE
RESCUE
RETAIL THEFT
RETAIL THEFT
RETAIL THEFT
RULINGS OF COURT
RULINGS OF THE COURT
SECOND DEGREE MURDER
SELF-DEFENSE
SELF DEFENSE: DUTY TO RETREAT
SELF-DEFENSE: DEADLY FORCE
SELF-DEFENSE: DEADLY FORCE
SELF-DEFENSE
SELF-DEFENSE
SELF DEFENSE
SELF-DEFENSE - INJURIES OF DEFENDANT
SELF DEFENSE OR DEFENSE OF OTHERS
SELF DEFENSE
SELF-DEFENSE - INJURIES OF DEFENDANT
SELF-DEFENSE
SEPARATE COUNTS
SEX DISCRIMINATION
SEXUAL ASSAULT
SEXUAL ASSAULT
SEXUAL ASSAULT
SEXUAL ACT: DEFINED
SIMPLE ASSAULT ON A LWA ENFORCEMENT OFFICER - 13 V.S.A. 1023 AND 1028
SIMPLE ASSAULT - 13 V.S.A. 1023(a)(1)
SIMPLE ASSAULT ON A POLICE OFFICER
SIMPLE ASSAULT--RECKLESSLY, BODILY INJURY DEFINED
SIMPLE ASSAULT
SPECIFIC INTENT
SPEEDING - 23 V.S.A. 1007(a)
STATEMENT: VOLUNTARINESS
STOLEN - DEFINED
SUPER ABUNDANCE OF PROOF
THE BURDEN OF PROOF
THE THEORY OF THE DEFENSE - EXPLAINED
THE GOOD FAITH DEFENSE - EXPLAINED
THEORY OF THE DEFENSE - EXPLAINED
to steal
TRESPASS TO PROPERTY - 13 V.S.A. 3701(c)
TYPES OF EVIDENCE
UNDER THE INFLUENCE
UNLAWFUL DELIVERY OF MARIJUANA-18 V.S.A.4230(b)(2)
UNLAWFUL MISCHIEF
UNLAWFUL MISCHIEF
VERDICT
VOLUNTARY MANSLAUGHTER
WEAKER OR LESS SATISFACTORY EVIDENCE
WEIGHT OF ACCOMPLICE TESTIMONY
willfully
WITNESSES