OJI-CR 409.13 Consciousness of Guilt
CONSCIOUSNESS OF GUILT. Testimony has been admitted indicating that the defendant (fled the [scene][describe jurisdiction]) (escaped from custody) (resisted arrest) (falsified his/her identity) (changed appearance) (intimidated a witness) (attempted to conceal a crime) (describe other conduct). You are instructed that (describe defendant’s conduct) alone does not raise a presumption of guilt, but it may tend to indicate the defendant’s (consciousness) (awareness) of guilt. If you find that the facts do not support the defendant (describe defendant’s conduct) or if you find that some other motive prompted the defendant’s conduct, or if you are unable to decide what the defendant’s motivation was, then you should not consider this evidence for this purpose. However, if you find that the facts support that the defendant engaged in such conduct and if you decide that the defendant was motivated by (a consciousness) (an awareness) of guilt, you may, but are not required to, consider that evidence in deciding whether the defendant is guilty of the crime(s) charged. You alone will determine what weight, if any, to give to this evidence.