COLJI-Crim. 42:46

The elements of the crime of installing object in lieu of air bag are:

1. That the defendant,

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

3. was an employee of a motor vehicle repair facility, and

4. installed or reinstalled, as part of a vehicle inflatable restraint

system,

5. any device that caused the motor vehicle’s diagnostic systems

to fail to warn that,

[6. the motor vehicle was equipped with a counterfeit

supplemental restraint system component.]

[6. the motor vehicle was equipped with a nonfunctional airbag.]

[6. no airbag was installed.]

[7. 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 installing object in lieu of air bag.

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 installing object in lieu of air

bag.