N.C.P.I.—Crim. 206.58

For you to find the defendant guilty of this offense, the State must

prove two things beyond a reasonable doubt:

First, that the defendant violated the following law of this State

governing the operation of motor vehicles. The law of this State include

(define the pertinent traffic law and enumerate the elements).1

And Second, that the defendant's violation of the law proximately

caused the victim's death. A proximate cause is a real cause, a cause

without which the victim's death would not have occurred, and one that a

reasonably careful and prudent person could foresee would probably

produce such [injury] [damage] or some similar injurious result. (The

defendant’s act need not have been the only cause, nor the nearest

cause. It is sufficient if it occurred with some other cause acting at the

same time, or in combination with, caused the death of the victim.)

If you find from the evidence beyond a reasonable doubt that on or

about the alleged date, the defendant (give the mandate for the offense

involved) and thereby violated the law of this State governing the

operation of a vehicle and that this violation proximately caused the

death of the victim, it would be your duty to return a verdict of guilty. If

you do not so find or have a reasonable doubt as to one or more of these

things, it would be your duty to return a verdict of not guilty.2

NOTE WELL: Where the indictment charges and the

evidence supports the violation of more than one traffic

law define and enumerate the elements of the charge

involved and adjust the mandate accordingly.