Ill. Pattern Jury Instr. (Criminal) 23.64

Urine--Accident Resulting In Injuries

To sustain the charge of aggravated driving with a drug, substance, or compound in blood

or urine, 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)] a vehicle, 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)]; and

Third Proposition: That the defendant, in [(so driving) (being in actual physical control

of)] a vehicle, was involved in a motor vehicle accident; and

Fourth Proposition: That the motor vehicle accident in which defendant was involved

resulted in [(great bodily harm) (permanent disability) (disfigurement)] to another person; and

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

vehicle while under the combined influence of alcohol and any drug or drugs to a degree which

rendered the defendant incapable of safely driving was the proximate cause of the [( great bodily

harm) (permanent disability) (disfigurement)] to the other person.

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.