The Tenth Circuit revises its conspiracy and kidnapping instructions

The Tenth Circuit revises its conspiracy and kidnapping instructions

The Tenth Circuit has posted an order revising its Criminal Pattern Jury Instructions. The changes were as follows:

Former Instruction 2.19 (Conspiracy 18 U.S.C. § 371) was eliminated and replaced with Instructions 2.19.1 (Conspiracy to Commit Offense 18 U.S.C. § 371) and 2.19.2 (Conspiracy to Defraud 18 U.S.C. § 371 (Second Clause)).

Instruction 2.55 (Kidnapping 18 U.S.C. § 1201(a)(1)) was substantially revised. The Comment explains that the change was made based on United States v. Murphy, 100 F.3d 1184 (10th Cir. 2024) ("holding" requires an appreciable temporal period of detention distinguished from that inherent in the commision of another offense).

(09/14/26) (permalink)

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The Tenth Circuit revises its conspiracy and kidnapping instructions The Tenth Circuit has posted an order revising its Criminal Pattern Jury Instructions. The changes were as follows: Former Instruction 2.19 (Conspiracy 18 U.S.C. § 371) was eliminated and replaced with Instructions 2.19.1 (Conspiracy to Commit Offense 18 U.S.C. § 371) and 2.19.2 (Conspiracy to Defraud 18 U.S.C. § 371 (Second Clause)). Instruction 2.55 (Kidnapping 18 U.S.C. § 1201(a)(1)) was substantially revised. The Comment explains that the change was made based on United States v. Murphy, 100 F.3d 1184 (10th Cir. 2024) ("holding" requires an appreciable temporal period of detention distinguished from that inherent in the commision of another offense). (09/14/26) (permalink)
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