MPJI-Cr 4:16.1

The defendant is charged with the crime of participation in a criminal gang [resulting in the death of a victim]. In order to convict the defendant of the crime of participation in a criminal gang [resulting in the death of a victim], the State must prove:
(1) that the defendant participated in a criminal gang, knowing that the members of the gang were engaged in a pattern of criminal gang activity;
(2) that the defendant knowingly and willfully participated in or directed another to participate in the crime of (insert underlying crime(s)); [and]
(3) the crime(s) of (insert underlying crime(s)) was committed for the benefit of, at the direction of, or in association with the criminal gang[.] [; and
(4) as a result of the commission of (insert underlying crime(s)), (the victim’s name) died.]
A “criminal gang” is a group or association of three or more people whose members individually or collectively engage in a pattern of criminal gang activity; have in common an overt or covert organization or command structure; and have as one of their primary objectives or activities the commission of one or more of the following underlying crimes: (insert underlying crime(s)).
A “pattern of criminal gang activity” means the commission of, attempted commission of, conspiracy to commit, or solicitation to commit two or more of the following crimes: (insert underlying crime(s)).