O96.4 Conspiracy to Encourage or Induce Aliens to Enter the United States

Official jury instruction text reproduced for information. It is not legal advice; the instruction given in a case depends on the facts and the court.

Instruction: O96.4
Statute: 8 U.S.C. § 1324(a)(1)(A)(v)(I)
Edition: Eleventh Circuit Pattern Jury Instructions (Criminal Cases), revised July 2026
Official source: Official PDF, page 685

Elements

Quoted word for word from the official text. Eleventh Circuit Pattern Jury Instructions (Criminal Cases), revised July 2026.

The Defendant can be found guilty only if all the following facts are proved beyond a reasonable doubt:

First: The defendant and one or more persons in some way agreed to try to accomplish a shared and unlawful plan;

Second: The defendant knew the unlawful purpose of the plan and willfully joined in it; and

Third: The object of the conspiracy was to encourage or induce an alien to come to, enter, or reside in the United States, knowing or in reckless disregard of the fact that such coming to, entry, and residence was or would be in violation of law.

Related practice page

Alien Smuggling, Transporting & Harboring (8 U.S.C. § 1324)

Official source: Official PDF, page 685

Official jury instruction text reproduced for information. It is not legal advice; the instruction given in a case depends on the facts and the court.