COLJI-Crim. 6-4:01

The elements of the crime of child abuse (knowingly or recklessly)

are:

1. That the defendant,

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

3. knowingly or recklessly,

4. caused an injury to a child’s life or health, or permitted a child

to be unreasonably placed in a situation that posed a threat of

injury to the child’s life or health, or engaged in a continued

pattern of conduct that resulted in malnourishment, lack of

proper medical care, cruel punishment, mistreatment, or an

accumulation of injuries that ultimately resulted in the death of

a child or serious bodily injury to a child.

[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 child abuse (knowingly or recklessly).

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 child abuse (knowingly or

recklessly).