IL · jury_instructions
Ill. Pattern Jury Instr. (Criminal) 7.10A
Issues In Aggravated Reckless Homicide
To sustain the charge of aggravated reckless homicide, the State must prove the following
propositions:
[1] First Proposition: That the defendant caused the death of [(__________) (two or
more persons as part of a single course of conduct)] [without lawful justification] by [(driving a
motor vehicle) (operating a snowmobile) (operating an all-terrain vehicle) (operating a
watercraft)]; and
Second Proposition: That the defendant [(drove a motor vehicle) (operated a
snowmobile) (operated an all-terrain vehicle) (operated a watercraft)] recklessly; and
Third Proposition: That the defendant [(drove a motor vehicle) (operated a snowmobile)
(operated an all-terrain vehicle) (operated a watercraft)] in a manner likely to cause death or
great bodily harm; and
Fourth Proposition: That in doing so, the defendant’s [(motor vehicle) (snowmobile) (all-terrain vehicle) (watercraft)] was upon a public thoroughfare where children pass going to and
from school when a school crossing guard is performing official duties.
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 caused the death of [(__________) (two or
more persons as part of a single course of conduct)] [without lawful justification] by driving a
motor vehicle; and
Second Proposition: That the defendant, drove the vehicle recklessly; and
Third Proposition: That the defendant drove the vehicle in a manner likely to cause death
or great bodily harm; and
Fourth Proposition: That in doing so, the defendant was driving in a construction or
maintenance zone.
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 caused the death of [(__________) (two or
more persons as part of a single course of conduct)] [without lawful justification] by [(driving a
motor vehicle) (operating a snowmobile) (operating an all-terrain vehicle) (operated a
watercraft)]; and
Second Proposition: That the defendant [(drove a motor vehicle) (operated a
snowmobile) (operated an all-terrain vehicle) (operated a watercraft)] recklessly; and
Third Proposition: That the defendant [(drove a motor vehicle) (operated a snowmobile)
(operated an all-terrain vehicle) (operated a watercraft)] in a manner likely to cause death or
great bodily harm; and
Fourth Proposition: That in doing so, the defendant failed or refused to comply with any
lawful order or direction of any [(authorized police officer) (traffic control aide)] engaged in
traffic control.
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 caused the death of two or more persons as part
of a single course of conduct [without lawful justification] by driving a vehicle; and
Second Proposition: That the defendant, while driving the vehicle, recklessly used an
incline in a roadway to cause the vehicle to become airborne.
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]
[5] First Proposition: That the defendant caused the death of a peace officer during
performance of his official duties as a peace officer [without lawful justification] by [(driving a
motor vehicle) (operating a snowmobile) (operating an all-terrain vehicle) (operating a
watercraft)]; and
Second Proposition: That the defendant [(drove a motor vehicle) (operated a
snowmobile) (operated an all-terrain vehicle) (operated a watercraft)] recklessly; and
Third Proposition: That the defendant [(drove a motor vehicle) (operated a snowmobile)
(operated an all-terrain vehicle) (operated a watercraft)] in a manner likely to cause death or
great bodily harm.
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]
[6] First Proposition: That the defendant caused the death of [(__________) (two or
more persons as part of a single course of conduct)] [without lawful justification] by driving a
vehicle; and
Second Proposition: That the defendant drove the vehicle recklessly; and
Third Proposition: That the defendant drove the vehicle in a manner likely to cause death
or great bodily harm; and
Fourth Proposition: That the defendant drove the 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, when approaching a stationary authorized emergency vehicle displaying
alternately flashing [(red) (red and white) (blue) (red and blue) (amber) (yellow)] warning lights;
and
Fifth 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.
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]
[7] First Proposition: That the defendant caused the death of [(__________) (two or
more persons as part of a single course of conduct)] [without lawful justification] by driving a
vehicle; and
Second Proposition: That the defendant drove the vehicle recklessly; and
Third Proposition: That the defendant drove the vehicle in a manner likely to cause death
or great bodily harm; and
Fourth Proposition: That the defendant drove the 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
Fifth 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.
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]
[8] First Proposition: That the defendant caused the death of a firefighter or other
emergency medical services personnel in the performance of their official duties [without lawful
justification] by driving a vehicle; and
Second Proposition: That the defendant drove the vehicle recklessly; and
Third Proposition: That the defendant drove the vehicle in a manner likely to cause death
or great bodily harm; and
Fourth Proposition: That the defendant drove the 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, when approaching a stationary authorized emergency vehicle displaying
alternately flashing [(red) (red and white) (blue, or red and blue lights) (amber or
yellow)] warning lights; and
Fifth 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.
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]
[9] First Proposition: That the defendant caused the death of a firefighter or other
emergency medical services personnel in the performance of their official duties [without lawful
justification] by driving a vehicle; and
Second Proposition: That the defendant drove the vehicle recklessly; and
Third Proposition: That the defendant drove the vehicle in a manner likely to cause death
or great bodily harm; and
Fourth Proposition: That the defendant drove the 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, or red and blue lights) (amber
or yellow)] warning lights; and
Fifth 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.
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.
Provenance
- Source
- illinoiscourts.gov
- Retrieved
- 2026-09-10
- Edition
- 2026-09-10
- Content hash
573605b1127ba496f6dde3a3de68c42ef7136f5c508f5c8f7836b616adc50dea
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