Haw. Pattern Jury Instr. (Criminal) 10.31

Serious Bodily Injury: H.R.S. § 708-841(1)(c)

(Applicable to offenses occurring on or after June 22, 2006)

[In Count (count number) of the Indictment/Complaint, the]

[The] Defendant, (defendant's name), is charged with the offense

of Robbery in the Second Degree.

A person commits the offense of Robbery in the Second

Degree if, in the course of [committing theft] [taking a motor

vehicle without consent], he/she recklessly inflicts serious

bodily injury on another.

There are two material elements of the offense of Robbery

in the Second Degree, each of which the prosecution must prove

beyond a reasonable doubt.

These two elements are:

1. That, on or about (date) in the [City and] County of

(name of county), the Defendant was in the course of [committing

theft] [taking a motor vehicle without consent]; and

2. That [, while doing so,] the Defendant recklessly

inflicted serious bodily injury on another.

A person commits theft if he/she obtains or exerts

unauthorized control over the property of another with intent to

deprive the person of the property.

An act shall be deemed “in the course of [committing theft]

[taking of a motor vehicle without consent]” if it occurs in an

attempt to [commit theft] [take a motor vehicle without consent]

in the commission of [theft][taking a motor vehicle without

consent] or in the flight after the attempt or commission.