COLJI-Crim. 9-1:68

The elements of bias-motivated crime (property) 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. caused damage to or destruction of the property of another

person.

[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 bias-motivated crime (property).

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

(property).