(N.J.S.A.
2C:13-2b) model jury charge
He/She
is accused of violation of our law, particularly 2C:13-2b. That section reads in pertinent part as
follows:
A
person is guilty of the crime of criminal restraint if he knowingly holds
another in a condition of involuntary servitude.
In order for you to find the
defendant ____________________, guilty of this offense, the State must prove
the essential elements of the offense beyond a reasonable doubt; they are:
1.
That the defendant,
____________________ knowingly held ____________________.
2. That the holding of
____________________, was in a condition of involuntary servitude.
A person acts knowingly with respect to the nature of his/her conduct or the
attendant is of that nature, or that such circumstances exist, or the person is
aware of a high probability of their existence.
A person acts knowingly with respect to a result of his/her conduct if he/she is aware that it is practically certain that his/her conduct will cause such
a result. "Knowing,"
"with knowledge" or equivalent terms have the same meaning.[2]
I have used the term involuntary servitude. Involuntary servitude is a condition of one
who is compelled by force, coercion, or imprisonment, and against his/her will, to labor for
another. The question of whether he/she is paid or not may be a factor.[3]
The creation by defendant
____________________, of circumstances resulting in a belief by
____________________, that he/she
must remain in a particular location, means holding in a condition of
involuntary servitude.
If after consideration of all of the evidence you are
convinced beyond a reasonable doubt that the defendant ____________________
knowingly held ____________________, and that said holding of
____________________, was in a condition of involuntary servitude, then your verdict
should be guilty.
If after a consideration of all of the evidence you find
that the state has failed to prove any element of the offense beyond a
reasonable doubt, then your verdict must be not guilty.
