Houston Texas Jury Instruction — Bank Robber— - Subsections (a) And (d) Alleged In Separate Counts When it comes to the legal proceedings of bank robbery cases in Houston, Texas, the jury instructions play a crucial role in guiding jurors on how to evaluate the evidence and deliberate on the charges brought against the defendant. In specific cases where subsections (a) and (d) of bank robbery are alleged in separate counts, jurors need to carefully consider the distinct elements and criteria required for each count. The Texas Penal Code provides detailed guidance on these subsections to ensure a fair and thorough trial. Subsection (a) of bank robbery pertains to the traditional act of unlawfully taking or attempting to take property or funds from a bank's custody and control. The instruction given to the jury will outline the specific elements that need to be proven beyond a reasonable doubt in order to convict the defendant under this count. These elements typically include proving that the defendant knowingly and intentionally engaged in acts that amounted to taking or attempting to take something of value from the bank, the property was owned by or in the care of the bank, and the defendant used intimidation or force or threatened to use force during the act. On the other hand, subsection (d) of bank robbery involves the additional element of causing serious bodily injury to another person in the course of the robbery. This count reflects a more severe offense and carries harsher penalties. Jurors will receive a separate set of instructions specifically addressing this count, highlighting the requirement to establish that the defendant caused serious bodily injury to any person, whether intentionally or recklessly, during the commission of the bank robbery. Moreover, the instructions may also specify what constitutes "serious bodily injury" in accordance with Texas law. It is important to note that the use of separate counts and instructions for subsections (a) and (d) allows the jury to assess each allegation independently. This ensures a fair trial by preventing the potential overlap of evidence or confusion regarding the different elements and criteria for each count. It provides clarity and enables jurors to reach a well-informed verdict on each alleged offense. In instances where subsection (a) and (d) of bank robbery are alleged in separate counts, the jury's duty is to carefully evaluate the evidence and determine whether the prosecution has proven beyond a reasonable doubt that the defendant committed each offense. Jurors should meticulously consider the testimony and evidence presented, including any witness statements, surveillance footage, or physical evidence, to assess the defendant's involvement in both counts. In conclusion, Houston Texas jury instructions for bank robbery cases involving subsections (a) and (d) alleged in separate counts provide essential guidance for jurors throughout the trial. By giving clear direction on the distinct elements and criteria required for each count, these instructions help ensure a fair and just verdict. Jurors play a critical role in carefully evaluating the evidence presented and determining the defendant's guilt or innocence in relation to each offense.