COLJI-Crim. 3-1:06

The elements of the crime of murder in the first degree (child under

twelve; position of trust) are:

1. That the defendant,

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

3. knowingly,

4. caused the death of a child who had not yet attained twelve

years of age, and

5. the defendant was in a position of trust with respect to the

child.

[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 murder in the first degree (child under twelve;

position of trust).

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 murder in the first degree

(child under twelve; position of trust).