COLJI-Crim. 9-3:35

The elements of the crime of interference with lawful distribution of

newspapers are:

1. That the defendant,

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

3. obtained or exerted control over more than five copies of an

edition of a newspaper from a newspaper distribution

container owned or leased by the newspaper publisher,

4. with the intent,

5. to prevent other individuals from reading that edition of the

newspaper, and

6. there was a notice on the newspaper or on the newspaper

distribution container that possession of more than five copies

with intent to prevent other individuals from reading that

edition of the newspaper was illegal.

[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 interference with lawful distribution of

newspapers.

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 interference with lawful

distribution of newspapers.