Jury Charges

Penal Code


Code of Criminal Procedure

Health & Safety

Transportation Code

With the advent of the State Bar of Texas' (SBOT) Criminal Pattern Jury Charges, TDCAA has determined that our jury charge bank has fulfilled its purpose. While the TDCAA charge bank will remain on the association's website for the indefinite future, the instructions will no longer be updated.

The SBOT Criminal Pattern Jury Charges are the cooperative effort of a committee of prosecutors, defense attorneys, trial judges, appellate judges, and law professors. Texas Criminal Pattern Jury Charges--Intoxication & Controlled Substances and Texas Pattern Jury Charges—Defenses contain general charge language, special instructions, a complete general charge and extensive commentary. These volumes will be regularly updated.

Prosecutors should consider adopting the SBOT criminal pattern jury charges and encouraging trial judges and defense attorneys to do the same. Though not mandatory, they provide the most comprehensive and defensible basis for generating criminal jury charges. The Criminal Pattern Jury Charges are available to order at http://texasbarbooks.net/tcpjc/ or by calling 800-204-2222 ext. 1411.

For users of TDCAA's existing bank, note that the the Jury Charge Bank is a series of Microsoft Word documents with suggested language and editor's notes for all Penal Code offenses (excluding Class C offenses), Controlled Substances Act offenses, and selected offenses found in the Transportation Code and Code of Criminal Procedure. The documents can be found by moving through the expandable headings for each code. Download the documents to your own computer, and then edit the draft carefully so that your final charge includes the information required for your specific case.

The base year used is 2001, meaning only changes made after 2001 will be reflected in the 2003 and 2005 folders. To ensure that the charge you are looking for is up to date, always begin looking for your charge in 2005 and work backwards. For example, if you are looking for Penal Code §31.11 (Tampering with Identification Numbers), begin with the 2007 folder. If there is no jury charge in that year, then check the 2003 folder. If, in the end, you can only find your charge in the 2001 folder, then no changes have been made since 2001 and that is the charge you should use. The user is responsible to exercise independent legal judgment when using these suggested charges as a guide in the creation of any specific charge

TDCAA's 2001 Jury Charge Bank was written by John Davis (El Paso County DA's Office) and Gail McConnell (Montgomery County DA's Office). Documents in the 2003-2007 Bank were written by Gail MConnell (Montgomery County DA's Office), Doug Arnold (Williamson County DA's Office), Kim Schaefer & Lisa Smith (Dallas County DA's Office). No new charges were written in 2009 due to the impending SBOT charges.