Maryland Pattern Jury Instructions-Criminal (MPJI-Cr)

3:27 Suppression, Alteration or Creation of Evidence as Consciousness of Guilt

You have heard that the defendant __________ evidence in this case. Such conduct is not enough by itself to establish guilt, but may be considered as evidence of guilt. It may be motivated by a variety of factors, some of which are fully consistent with innocence.

You must first decide whether the defendant __________ evidence in this case. If you find that the defendant __________ evidence in this case, then you must decide whether this action shows a consciousness of guilt.