M Crim JI 20.33 Indecent Exposure
(1) The defendant is charged with the crime of indecent exposure. To prove this charge, the prosecutor must prove each of the following elements beyond a reasonable doubt:
(2) First, that the defendant exposed [his / her] [state part of body].
(3) Second, that the defendant knew that [he / she] was exposing [his / her] [state
part of body].
[Use the following paragraph only if a violation of MCL 750.335a(2)(b) is charged.]
(4) Third, that the defendant was fondling [his / her] [genitals / pubic area / buttocks / breasts*].
(5) [Third / Fourth], that the defendant did this in a place under circumstances in which another person might reasonably have been expected to observe it and which created a substantial risk that someone might be offended or in a place where such exposure is likely to be an offense against your community’s generally accepted standards of decency and morality. In determining this, you must think about the nature of the act and all of the circumstances surrounding the act. [State any other relevant factors, e.g., the age and experience of the persons who observed the act, the purpose of the act, etc.]