Ill. Pattern Jury Instr. (Criminal) 23.28

To sustain the charge of [(driving under the influence of alcohol) (driving under the

influence of drugs) (driving under the combined influence of alcohol and drugs) (driving with an

alcohol concentration of 0.08 or more) (driving with a drug, substance, or compound in blood or

urine)] involving a motor vehicle accident, the State must prove the following propositions:

First Proposition: That the defendant [(drove) (was in actual physical control of )] a

vehicle; and

Second Proposition: That at the time the defendant [(drove) (was in actual physical

control of )] the vehicle, the defendant [(was under the influence of alcohol) (was under the

influence of any drug or combination of drugs to a degree which rendered him incapable of

safely driving) (was under the combined influence of alcohol and any drug or drugs to a degree

which rendered him incapable of safely driving) (had an alcohol concentration in his blood or

breath of 0.08 or more) (had any amount of a drug, substance, or compound in his blood or urine

resulting from the unlawful use or consumption of [( cannabis) (____, a controlled substance )])];

and

Third Proposition: That the defendant was involved in a motor vehicle accident; and

Fourth Proposition: That the motor vehicle accident resulted in [(great bodily harm)

(permanent disability) (permanent disfigurement)] to another; and

Fifth Proposition: That the defendant's act of [(driving) (being in actual physical control

of)] a vehicle while [(under the influence of alcohol) (under the influence of any drug or

combination of drugs to a degree which rendered him incapable of safely driving) (under the

combined influence of alcohol and any drug or drugs to a degree which rendered him incapable

of safely driving) (the alcohol concentration in his blood or breath was 0.08 or more) (there was

any amount of a drug, substance, or compound in his blood or urine resulting from the unlawful

use or consumption of [( cannabis) (____, a controlled substance )])] was the proximate cause of

the [(great bodily harm) (permanent disability) (permanent disfigurement)].

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.