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CRM 1000-1499

1109. Sample Jury Instruction for Use of Interstate Commerce Facilities in the Commission of Murder-for-Hire

The defendant is charged in Count _____ of the indictment with use of interstate commerce facilities in the commission of murder-for-hire, in violation of section 1958 of Title 18 of the United States Code. In order for you to find the defendant guilty of this charge, the government must prove beyond a reasonable doubt the following elements of the offense:

  1. That the defendant at or about the time charged in the indictment travelled or caused another to travel in interstate commerce or used or caused another to use the mail or any facility in interstate or foreign commerce;
  2. That the travel or use of the mail or interstate facility was done with the intent that a murder be committed in violation of the laws of any State or of the United States; and
  3. That anything of pecuniary value was received or promised or agreed to be paid as consideration for the murder.

[cited in JM 9-60.900]