N.C.P.I.—Crim. 235.44

The defendant, has been charged with use of an unmanned aircraft

system near a forest fire causing serious [physical] [mental] injury.1

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

four things beyond a reasonable doubt:

First, that the defendant was a [person] [entity] [State agency].

Second, that the defendant used an unmanned aircraft system.

Third, that the defendant did so within a [horizontal]2 [vertical] distance

of 3,000 feet from any forest fire within the jurisdiction of the North Carolina

Forest Service.

And Fourth, that the use of the unmanned aircraft system was a

proximate cause of serious [physical] [mental] injury to the victim. Serious

physical or mental injury is physical or mental injury that causes great pain

and suffering.3 A proximate cause is a real cause, a cause without which the

victim's injury 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 last or nearest cause. It is sufficient if it occurred with

some other cause acting at the same time, which, in combination with, caused

the injury to the victim.)

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

about the alleged date, the defendant was a [person] [entity] [State agency],

that the defendant used an unmanned aircraft system within a [horizontal]

[vertical] distance of 3,000 feet from any forest fire within the jurisdiction of

the North Carolina Forest Service, and that the use of the unmanned aircraft

system was a proximate cause of serious [physical] [mental] injury to 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.4