COLJI-Crim. 3-2:27

The elements of the crime of vehicular assault (under the influence)

are:

1. That the defendant,

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

3. operated or drove a motor vehicle,

4. while under the influence of alcohol or one or more drugs, or a

combination of both alcohol and one or more drugs,

5. and such conduct was the proximate cause of serious bodily

injury to another person.

[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 vehicular assault (under the influence).

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 vehicular assault (under the

influence).