COLJI-Crim. 3.5:11

The elements of the crime of careless driving resulting in unlawful

termination of pregnancy are:

1. That the defendant,

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

3. drove a [motor vehicle] [bicycle] [electrical assisted bicycle]

[electric scooter] [low-power scooter],

4. in a careless and imprudent manner, without due regard for the

width, grade, curves, corners, traffic, and use of the streets and

highways and all other attendant circumstances, and

5. caused the unlawful termination of a pregnancy of a woman.

[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 careless driving resulting in unlawful termination

of pregnancy.

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 careless driving resulting in

unlawful termination of pregnancy.