COLJI-Crim. 8-6:15

The elements of the crime of willful harassment of a juror by an

employer are:

1. That the defendant,

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

3. willfully,

4. deprived an employed juror of employment or any incidents or

benefits of employment, or harassed, threatened, or coerced an

employee because the employee received a juror summons,

responded to a juror summons, performed any obligation or

election of juror service as a trial juror or grand juror, or

exercised his [her] her right to [insert description of right

exercised under the “Colorado Uniform Jury Selection and

Service Act”, Article 71 of Title 13].

[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 willful harassment of a juror by an employer.

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 willful harassment of a juror by

an employer.