Ill. Pattern Jury Instr. (Criminal) 23.76B

Blood, Or Urine--Accident Resulting In Bodily Harm To A Child Under The Age Of 16

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

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 breath,

blood, or urine resulting from the unlawful use or consumption of [(cannabis) (____, a controlled

substance) (an intoxicating compound) (methamphetamine)]; 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 16; 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 16 being transported by the defendant; and

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

vehicle while there was any amount of a drug, substance, or compound in his breath, blood or

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

substance) (an intoxicating compound) (methamphetamine)] was the proximate cause of the

bodily harm to the child under the age of 16 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.