COLJI-Crim. 13:15

The elements of the crime of unlawful purchase or sale of commodity

metals or detached catalytic converters (scrap theft alert system) are:

1. That the defendant,

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

3. was a purchaser of commodity metals or detached catalytic

converters, and

[4. failed to sign up with the scrap theft alert system maintained by

the Institute of Scrap Recycling Industries, Incorporated, to

receive alerts regarding thefts of commodity metals or detached

catalytic converters in his [her] geographic area.]

[4. failed to download and maintain the scrap metal theft alerts

generated by the scrap theft alert system maintained by the

Institute of Scrap Recycling Industries, Incorporated.]

[4. failed to use the alerts generated by the scrap theft alert system

maintained by the Institute of Scrap Recycling Industries,

Incorporated, to identify potentially stolen commodity metals

or detached catalytic converters.]

[4. failed to train his [her] employees to use the alerts generated by

the scrap theft alert system maintained by the Institute of Scrap

Recycling Industries, Incorporated, during his [her] daily

operations.]

[4. failed to maintain for ninety days copies of any theft alerts

received and downloaded pursuant to the scrap theft alert

system maintained by the Institute of Scrap Recycling

Industries, Incorporated.]

[4. failed to maintain documentation that he [she] educates

employees about, and provides to employees, scrap theft

alerts.]

[5. 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 purchase or sale of commodity metals or

detached catalytic converters (scrap theft alert system).

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 purchase or sale of

commodity metals or detached catalytic converters (scrap theft alert

system).