COLJI-Crim. 9-1:67

The elements of bias-motivated crime (fear) are:

1. That the defendant,

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

3. with the intent,

4. to intimidate or harass another person, in whole or in part,

because of that person’s actual or perceived race, color, religion,

ancestry, national origin, physical or mental disability, sexual

orientation, or transgender identity,

5. knowingly,

6. by words or conduct,

7. placed another person in fear of imminent lawless action

directed at that person, or that person’s property,

8. and such words or conduct were likely to produce bodily injury

to that person or damage to that person’s property.

[9. 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 bias-motivated crime (fear).

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 bias-motivated crime (fear).