SEQ CHAPTER \h \r 1CR28-181 12/05/05
ESCAPE FROM CORRECTIONAL FACILITY OR LOCKUP – 13 V.S.A. § 1501(a)(1)
The State has charged (Def)_______________ with escape from a [correctional facility] [local lockup], 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) was in lawful custody within a [correctional facility] [local lockup]; and
(3) [he] [she] escaped from that facility.
The first essential element is that (Def)_______________ is the person who committed the alleged acts.
The second essential element is that (Def)_______________ was in lawful custody within a [correctional facility] [local lockup]. Lawful custody means that (Def)_______________ was deprived of [his] [her] freedom through a court order.
The last essential element is that (Def)_______________ escaped from that facility. To escape means to voluntarily depart from lawful custody. Here the State alleges that (Def)_______________ escaped from lawful custody in (facility)_______________.
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.