COLJI-Crim. 8-7:09

The elements of the crime of retaliation against a juror are:

1. That the defendant,

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

3. used a threat, an act constituting the crime of harassment, or an

act of harm or injury upon any person or property,

4. directed to, or committed upon, a juror who had served for a

criminal or civil trial involving the defendant or a person or

persons on whose behalf the defendant was acting, a member

of the juror’s family, an individual in close relationship to the

juror, or an individual residing in the same household with the

juror,

5. as retaliation or retribution against the juror.

[6. 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 retaliation against a juror.

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 retaliation against a juror.