Ill. Pattern Jury Instr. (Criminal) 11.16

Victims-As Of July 1, 2011

To sustain the charge of aggravated battery, the State must prove the following

propositions:

First Proposition: That the defendant [(intentionally) (knowingly)] [(caused bodily harm

to ____) (made physical contact of an insulting or provoking nature with ____)]; and

[1] Second Proposition: That the defendant used a deadly weapon other than by the

discharge of a firearm.

[or]

[2] Second Proposition: That the defendant was hooded, robed, or masked in such a

manner as to conceal his identity.

[or]

[3] Second Proposition: That the defendant knew ____ to be a teacher or other person

employed in a school; and

Third Proposition: That ____ was on the grounds of a school or grounds adjacent to a

school, or in any part of a building used for school purposes.

[or]

[4] Second Proposition: That the defendant knew ____ to be a supervisor, director,

instructor, or other person employed in a park district; and

Third Proposition: That ____ was on the grounds of the park, or on grounds adjacent to

the park, or in any part of a building used for park purposes.

[or]

[5] Second Proposition: That the defendant knew ____ to be a caseworker, investigator,

or other person employed by the State Department of Public Aid or a County Department of

Public Aid; and

Third Proposition: That ____ was

[a] on the grounds of a public aid office or grounds adjacent to a public aid office.

[or]

[b] in any part of a building used for public aid purposes.

[or]

[c] on the grounds of the home of a [(public aid applicant or recipient) (person

being interviewed or investigated in the employee's discharge of his duties)]

[or]

[d] on grounds adjacent to the home of the [(public aid applicant or recipient)

(person being interviewed or investigated in the employee's discharge of his

duties)].

[or]

[e] in any part of a building in which the applicant, recipient, or other such person

resides or is located.

[or]

[6] Second Proposition: That the defendant knew ____ to be a [(peace officer)

(correctional institution employee) (fireman) (person summoned or directed by a peace officer)];

and

[a] Third Proposition: That the defendant [(knew that ____ was engaged in the

execution of) (harmed ____ to prevent him from performing) (harmed ____ in retaliation

for his performing)] official duties.

[or]

[b] Third Proposition: That the defendant harmed that person [(while the peace

officer was engaged in the execution of) (to prevent the peace officer from performing)

(to retaliate for that person helping the peace officer perform)] official duties.

[or]

[7] Second Proposition: That the defendant knew ____ to be [(an emergency medical

technician) (and ambulance driver) (a medical assistant) (a first aid attendant)]; and

Third Proposition: That the defendant [(knew that ____ was engaged in the performance

of his) (harmed ____ to prevent him from performing) (harmed ____ in retaliation for his

performing)] official duties.

[or]

[8a] Second Proposition: That the defendant did so while on or about [(a public way)

(public property) (a public place of accommodation) (a public place of amusement)].

[or]

[8b] Second Proposition: That when the defendant did so, ____ was on or about [(a

public way) (public property) (a public place of accommodation) (a public place of amusement)].

[or]

[9] Second Proposition: That the defendant knew ____ to be the [(driver)

(operator)(employee) (passenger)] of any transportation facility or system engaged in the

business of transportation of the public for hire; and

Third Proposition: That ____ was [( then performing in such capacity) (then using such

public transportation as a passenger) (then using any area of any description designated by the

transportation facility or system as a vehicle boarding, departure, or transfer location)].

[or]

[10] Second Proposition: That at the time defendant did so, ____ was an individual of 60

years of age or older.

[or]

[11] Second Proposition: That the defendant knew ____ to be pregnant.

[or]

[12] Second Proposition: That the defendant knew ____ to be a judge whom he intended

to harm as a result of the judge's performance of his or her official duties as a judge.

[or]

[13] Second Proposition: That the defendant knew ____ to be an employee of the Illinois

Department of Children and Family Services engaged in the performance of his or her official

duties as such an employee.

[or]

[14] Second Proposition: That the defendant knew ____ to be a person who was

physically handicapped.

[or]

[15] Second Proposition: That the defendant knew ____ to be a merchant who was

detaining the defendant for an alleged commission of retail theft.

If you find from your consideration of all the evidence that each one of these propositions has

been proved beyond a reasonable doubt, you should find the defendant guilty.

If you find from your consideration of all the evidence that any one of these propositions has not

been proved beyond a reasonable doubt, you should find the defendant not guilty.