COLJI-Crim. 42:01.3

The elements of the crime of operating vehicle after circumventing

interlock device are:

1. That the defendant,

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

3. was a person whose privilege to drive was restricted to the

operation of a motor vehicle equipped with an approved

ignition interlock device, and

[4. operated a motor vehicle other than a motor vehicle equipped

with an approved ignition interlock device.]

[4. circumvented or attempted to circumvent the proper use of an

approved ignition interlock device.]

[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 operating vehicle after circumventing interlock

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 operating vehicle after

circumventing interlock device.