COLJI-Crim. 9-1:60

The elements of the crime of failure or refusal to leave premises or

property upon request of a peace officer (another person; no deadly

weapon) are:

1. That the defendant,

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

3. knowingly,

4. barricaded or refused police entry to any premises or property

through use of, or threatened use of, force, and

5. refused or failed to leave any premises or property upon being

requested to do so by a peace officer,

6. who had probable cause to believe a crime was occurring and

that defendant constituted a danger to himself [herself] or

others, and

7. in the same criminal episode,

8. knowingly,

9. held another person hostage or confined or detained another

person without that person’s consent,

10. without proper legal authority, and

11. without the use of a deadly weapon.

[12. 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 failure or refusal to leave premises or property

upon request of a peace officer (another person; no deadly weapon).

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 failure or refusal to leave

premises or property upon request of a peace officer (another person; no

deadly weapon).