COLJI-Crim. 9-1:22

The elements of the crime of targeted residential picketing (sign or

placard) are:

1. That the defendant,

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

3. engaged in targeted picketing, and

4. held, carried, or otherwise displayed on his [her] person a sign

or placard that was greater in size than six square feet, or more

than one sign or placard,

5. while he [she] was on a street or sidewalk in a residential area,

and

6. had previously been ordered by a peace officer or law

enforcement official to move, disperse, or take other

appropriate action, by means of a warning that included an

indication of the necessary conditions for signs or placards, and

7. failed to promptly comply with the warning.

[8. 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 targeted residential picketing (sign or placard).

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 targeted residential picketing

(sign or placard).