COLJI-Crim. 9-1:48

The elements of the crime of endangering public transportation

(threat) are:

1. That the defendant,

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

3. knowingly,

4. on a public conveyance,

5. threatened any operator, crew member, attendant, or

passenger,

6. with death or imminent serious bodily injury; or with a deadly

weapon or with words or actions intended to induce belief that

he [she] was armed with a deadly weapon.

[7. 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 endangering public transportation (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 endangering public

transportation (threat).