COLJI-Crim. 16:01

The elements of the crime of failure to identify seller of a valuable

article are:

1. That the defendant,

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

3. knowingly,

4. was a purchaser, and

5. purchased a valuable article,

6. without first securing at least one of the following types of

identification from the seller: a valid Colorado driver’s license;

an identification card issued by the Colorado Department of

Revenue; a valid driver’s license, containing a picture, issued

by another state; a military identification card; a valid passport;

an alien registration card; or a nonpicture identification

document issued by a state or federal government entity where

the defendant also obtained a clear imprint of the seller’s right

index finger.

[7. 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 failure to identify seller of a valuable article.

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 failure to identify seller of a

valuable article.