COLJI-Crim. 12-1:46.4

The elements of the crime of unlawful storage of a firearm in a

vehicle (leaving firearm unattended) are:

1. That the defendant,

2. in the State of Colorado, at or about the date and place charged,

3. knowingly,

4. left a firearm that was not a handgun in an unattended vehicle,

and

5. the firearm was not in a locked hard-sided container or locked

soft-sided container that was in a locked vehicle, the locked

trunk of a locked vehicle, or a locked recreational vehicle.

[6. and that the defendant’s conduct was not legally authorized by

the affirmative defense[s] in Instruction[s] ___.]

After considering all the evidence, if you decide the prosecution has

proven each of the elements beyond a reasonable doubt, you should find

the defendant guilty of unlawful storage of a firearm in a vehicle (leaving

firearm unattended).

After considering all the evidence, if you decide the prosecution has

failed to prove any one or more of the elements beyond a reasonable doubt,

you should find the defendant not guilty of unlawful storage of a firearm

in a vehicle (leaving firearm unattended).