Ill. Pattern Jury Instr. (Criminal) 23.64A

In Breath, Blood Or Urine--Accident Resulting In Death

To sustain the charge of aggravated driving with a drug, substance, or intoxicating

compound in breath, blood or urine, the State must prove the following propositions:

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

[(a)(an)] [(motor vehicle) (snowmobile) (all terrain vehicle) (watercraft)]; and

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

control of)] [(a)(an)] [(motor vehicle) (snowmobile) (all terrain vehicle) (watercraft)], there was

any amount of a drug, substance, or intoxicating compound in his breath, blood or urine resulting

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

intoxicating compound)]; and

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

of)] [(a)(an)] [(motor vehicle) (snowmobile) (all terrain vehicle) (watercraft)], was involved in an

accident; and

Fourth Proposition: That the accident in which defendant was involved resulted in death

to another person; and

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

[(a)(an)] [(motor vehicle) (snowmobile) (all terrain vehicle) (watercraft)] while there was any

amount of a drug, substance, or intoxicating compound in his breath, blood, or urine was a

proximate cause of the death 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.