The state accuses the defendant of having committed the offense of making a false report to law enforcement.

Relevant Statutes

A person commits the offense of making a false report to law enforcement if the person, with intent to deceive, knowingly makes a false statement that is material to a criminal investigation and makes the statement to a peace officer or federal special investigator conducting the investigation or to any employee of a law enforcement agency who is authorized by the agency to conduct the investigation and whom the defendant knows is conducting the investigation.

Definitions

Knowingly Making a False Statement

“Knowingly making a false statement” means to make a false statement with awareness that the statement is being made and that it is false.

Intent to Deceive

“Intent to deceive” means the conscious objective or desire to deceive.

Statement

“Statement” means any representation of fact.

Law Enforcement Agency

“Law enforcement agency” means an agency of the state or an agency of a political subdivision of the state authorized by law to employ peace officers.

Application of Law to Facts

You must determine whether the state has proved, beyond a reasonable doubt, four elements. The elements are that—

1. the defendant, in [county] County, Texas, on or about [date], knowingly made a false statement;
2. the statement was made to [name], [a peace officer/insert other type of officer or investigator] conducting a criminal investigation;
3. the statement was material to the criminal investigation; and
4. the defendant had the intent to deceive.

You must all agree on elements 1 through 4 listed above.

If you all agree the state has failed to prove, beyond a reasonable doubt, one or more of elements 1 through 4 above, you must find the defendant “not guilty.”

If you all agree the state has proved, beyond a reasonable doubt, each of the four elements listed above, you must find the defendant “guilty.”

[Insert any other instructions raised by the evidence. Then continue with the verdict form found in CPJC 2.1, the general charge.]