COLJI-Crim. 4-4:34

The elements of the crime of unlawful possession of a theft detection

shielding device or a theft detection deactivating device are:

1. That the defendant,

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

3. possessed a theft detection shielding device or a theft detection

deactivating device,

[4. with the intent to use the device possessed in the commission of

an offense involving theft.]

[4. with the knowledge that some person intended to use the

device possessed in the commission of an offense involving

theft.]

[5. 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 unlawful possession of a theft detection shielding

or theft detection deactivating device.

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 unlawful possession of a theft

detection shielding or theft detection deactivating device.