COLJI-Crim. 9-2:05

The elements of the crime of cruelty to a service animal or a law

enforcement animal are:

1. That the defendant,

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

[3. knowingly, recklessly, or with criminal negligence,

4. overdrove, overloaded, overworked, tormented, deprived of

necessary sustenance, unnecessarily or cruelly beat, allowed to

be housed in a manner that resulted in chronic or repeated

serious physical harm, carried or confined in or upon any

vehicles in a cruel or reckless manner, engaged in a sexual act

with an animal, or otherwise mistreated or neglected any

animal, or caused or procured it to be done, or, having the

charge or custody of any animal, failed to provide it with

proper food, drink, or protection from the weather consistent

with the species, breed, and type of animal involved, or

abandoned an animal,]

[3. intentionally,

4. abandoned a dog or cat,]

5. and the animal was a service animal or a law enforcement

animal, whether or not the service animal or law enforcement

animal was on duty.

[6. 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 cruelty to a service animal or a law enforcement

animal.

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 cruelty to a service animal or a

law enforcement animal.