CR28-861 07/12/26

UNLAWFUL TRESPASS (LOCKED BUILDING), 13 V.S.A. § 3705(d)

The State has charged (Def)_______________ with unlawful trespass, as follows:

[Read the charge.]

Every crime is made up of essential elements. Before (Def)_______________ can be found guilty of the charge, the State must have proven each of the essential elements beyond a reasonable doubt. In this case, the essential elements are that on the date and at the place alleged,

(1) (Def)_______________;

(2) entered a [building other than a residence] [residence]; and

(3) [the access of the building was normally locked, whether or not the access was actually locked] [(Def)_______________ did so in violation of an order of any court of competent jurisdiction in this State].

The first essential element is that (Def)_______________ is the person who committed the alleged acts.

The second essential element is that (Def)_______________ entered a [building other than a residence] [residence].

The last essential element is that [the access of the building was normally locked, whether or not the access was actually locked] [(Def)_______________ entered the residence in violation of an order of any court of competent jurisdiction in this State].

All of the elements of the offense must have been present at the same time. If the State has not proven each of the essential elements of the charge beyond a reasonable doubt, then you must find (Def)_______________ not guilty. However, if the State has proven all of the essential elements beyond a reasonable doubt, you must return a verdict of guilty.