Ill. Pattern Jury Instr. (Criminal) 23.72B

In Bodily Harm To A Child Under The Age Of 16

To sustain the charge of aggravated driving under the influence of drugs, 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, the defendant was under the influence of any drug or combination of drugs

to a degree which rendered the defendant incapable of safely driving; and

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

of)] a vehicle, the defendant was transporting a child under the age of sixteen; and

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

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

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

resulted in bodily harm to the child under the age of sixteen being transported by the defendant;

and

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

vehicle while under the influence of any drug or combination of drugs to a degree which

rendered him incapable of safely driving was the proximate cause of the bodily harm to the child

under the age of sixteen being transported by the defendant.

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.