[Insert instructions for underlying offense.]

Voluntariness of Statement

You have heard evidence that the defendant made a statement [describe statement, e.g., to Detective [name] on [date]]. You have also heard testimony that certain evidence—specifically [describe evidence, e.g., a firearm]—was obtained as a result of that statement. If you find the defendant did make the statement, you may consider that statement and any evidence obtained as a result of that statement against the defendant only if you resolve a preliminary question in favor of the state.

A statement of an accused and evidence obtained as a result of such a statement may be considered against the accused only if the statement was freely and voluntarily made without compulsion or persuasion.

Therefore, you may consider any statement you believe the defendant made and any evidence obtained as a result of such a statement only if you first all agree the state has proved, beyond a reasonable doubt, that the defendant made the statement freely and voluntarily without compulsion or persuasion.

Unless you find the state has proved, beyond a reasonable doubt, that the statement [describe statement, e.g., to Detective [name] on [date]] was in fact made and that it was made freely and voluntarily, you must not consider the statement or [describe evidence, e.g., the firearm] obtained as a result of that statement for any purpose.

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