COLJI-Crim. 3-2:27.5

The elements of the crime of vehicular assault (driving while ability

impaired) 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 [his] [her] ability was impaired by alcohol or one or more

drugs, or a combination of both alcohol and one or more drugs,

and

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

injury of another.

[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 (driving while ability impaired).

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 (driving

while ability impaired).