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CO · jury_instructions

COLJI-Crim. 3-4:52

SEXUAL ASSAULT ON A CLIENT BY A PSYCHOTHERAPIST (THERAPEUTIC DECEPTION)

activein force · 2026-02-25 – presentcompiled-edition

The elements of sexual assault on a client by a psychotherapist

(therapeutic deception) are:

1. That the defendant,

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

3. knowingly,

4. subjected a person to any sexual contact,

5. when the defendant was a psychotherapist, and

6. the person was a client of the defendant, and

7. the sexual contact occurred by means of therapeutic deception.

[8. 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 sexual assault on a client by a psychotherapist

(therapeutic deception).

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 sexual assault on a client by a

psychotherapist (therapeutic deception).

History

COLJI-Crim. (2025), Colorado Supreme Court Model Criminal Jury Instructions Committee. The committee's page: "The 2025 edition was published online on February 25, 2026." © 2025 Supreme Court of Colorado for the State of Colorado.

Provenance

Source
www.coloradojudicial.gov
Retrieved
2026-09-24
Edition
crim-2026-02-25
Content hash
9e22caaa18273768fef046179e57ab90bd110f585275f3d69b50d3d38aeac5ea
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