COLJI-Crim. 23:02

The elements of the crime of recruitment of a juvenile for a criminal

street gang (prevent from leaving) are:

1. That the defendant,

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

3. was eighteen years of age or older, and

4. knowingly,

5. by use of force, threat, or intimidation directed at any person,

or by the infliction of bodily injury upon any person,

6. prevented a person younger than eighteen years of age from

leaving a criminal street gang.

[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 recruitment of a juvenile for a criminal street gang

(prevent from leaving).

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 recruitment of a juvenile for a

criminal street gang (prevent from leaving).