COLJI-Crim. 18:81

The elements of the crime of inducing consumption by fraudulent

means are:

1. That the defendant,

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

3. surreptitiously, or by means of fraud, misrepresentation,

suppression of truth, deception, or subterfuge,

4. caused any other person to unknowingly consume or receive

the direct administration of any controlled substance.

[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 inducing consumption by fraudulent means.

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 inducing consumption by

fraudulent means.