COLJI-Crim. 9-1:70

The elements of the crime of prohibited activities near a health care

facility are:

1. That the defendant,

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

3. knowingly,

4. approached to within eight feet of another person,

5. without that person’s consent,

6. for the purpose of passing a leaflet or handbill to, displaying a

sign to, or engaging in oral protest, education, or counseling

with that person,

7. in the public way or sidewalk area within a radius of one

hundred feet from any entrance door to a health care facility.

[8. 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 prohibited activities near a health care facility.

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 prohibited activities near a

health care facility.