Does Anybody have a Capital Maurder Jury charge (victim under six)? I would appreciate the help.

Check out the Jury Charges link on the top of the TDCAA website. Under "Penal Code" and then Ch. 19, you will find a sample for a child victim capital charge. Also, if you have it, look at Vol. 8 of the Texas Practice Series, Criminal Forms and Trial Manual, by McCormick, Blackwell and Blackwell. It is a brown set of books, and it contains a lot of sample criminal jury instructions.

Remember in the under six provision the D need not have the specific intent to cause death; a knowing act is sufficient. We here have had better outcomes alleging only a knowing state of mind. Jurors find it difficult to believe someone could have the conscious objective or desire to cause the death of a child under six.