Ill. Pattern Jury Instr. (Criminal) 23.80

To sustain the charge of driving on approach to an emergency vehicle, the State must

prove the following propositions:

[1] First Proposition: That the defendant drove a vehicle on a highway having at least

four lanes with not less than two lanes proceeding in the same direction as the defendant’s

vehicle; and

Second Proposition: That while driving, the defendant approached a signaling, stationary

authorized emergency vehicle displaying alternately flashing [(red) (red and white) (blue) (red

and blue) (amber) (yellow)] warning lights; and

Third Proposition: That the defendant failed to proceed with due caution, reduce the

speed of the vehicle, maintain a safe speed for road conditions, be prepared to stop, and leave a

safe distance until safely passed the authorized emergency vehicle, and yield the right-of-way by

making a lane change into a lane not adjacent to that of the authorized emergency vehicle, if

possible, with due regard for safety and traffic conditions; and

Fourth Proposition: That in doing so, the defendant caused damage to another vehicle.

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.

[or]

[2] First Proposition: That the defendant drove a vehicle on a roadway where changing

lanes would be impossible or unsafe, when approaching a stationary authorized emergency

vehicle displaying alternately flashing [(red) (red and white) (blue) (red and blue) (amber)

(yellow)] warning lights; and

Second Proposition: That the defendant failed to proceed with due caution, reduce the

speed of the vehicle, maintain a safe speed for road conditions, and leave a safe distance until

safely past the authorized emergency vehicle; and

Third Proposition: That in doing so, the defendant caused damage to another vehicle.

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.

[or]

[3] First Proposition: That the defendant drove a vehicle on a highway having at least

four lanes with not less than two lanes proceeding in the same direction as the defendant’s

vehicle; and

Second Proposition: That while driving, the defendant approached a signaling, stationary

authorized emergency vehicle displaying alternately flashing [(red) (red and white) (blue) (red

and blue) (amber) (yellow)] warning lights; and

Third Proposition: That the defendant failed to proceed with due caution, reduce the

speed of the vehicle, maintain a safe speed for road conditions, be prepared to stop, and leave a

safe distance until safely passed the authorized emergency vehicle, and yield the right-of-way by

making a lane change into a lane not adjacent to that of the authorized emergency vehicle, if

possible, with due regard for safety and traffic conditions; and

Fourth Proposition: That in doing so, the defendant caused the injury or death of another

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.

[or]

[4] First Proposition: That the defendant drove a vehicle on a roadway where changing

lanes would be impossible or unsafe, when approaching a stationary authorized emergency

vehicle displaying alternately flashing [(red) (red and white) (blue) (red and blue) (amber)

(yellow)] warning lights; and

Second Proposition: That the defendant failed to proceed with due caution, reduce the

speed of the vehicle, maintain a safe speed for road conditions, and leave a safe distance until

safely past the authorized emergency vehicle; and

Third Proposition: That in doing so, the defendant caused the injury or death of another

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.