COLJI-Crim. 9-1:26

The elements of the crime of interference with staff, faculty, or

students of educational institutions (credible threat) are:

1. That the defendant,

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

3. knowingly,

4. made or conveyed to another person a credible threat to cause

death, or to cause bodily injury with a deadly weapon,

5. against a person the defendant knew or believed to be a

student, school official, employee of an educational institution,

or an invitee who was on the premises of an educational

institution.

[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 interference with staff, faculty, or students of

educational institutions (credible threat).

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 interference with staff, faculty,

or students of educational institution (credible threat).