N.C.P.I.—Crim. 239.65

The defendant has been charged with permitting a child under 16 years

of age to [operate] [be a passenger on] a bicycle 3 without a protective bicycle

helmet. 4

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 the [parent) [legal guardian) of the child.

Second, that the child [operated] 5 [was a passenger on] 6 a bicycle.

Third, that the defendant knowingly permitted the child to [operate) [be

a passenger on] the bicycle while not wearing a protective bicycle helmet of

good fit fastened securely upon the head with the straps of the helmet.

And Fourth, that at the time the child was [operating) [a passenger on]

a bicycle without a protective bicycle helmet, he was below the age of 16

years.

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

about the alleged date the defendant was the [parent) [legal guardian) of the

child, who at that time was below the age of 16 years, and that the defendant

knowingly permitted the child to [operate] [be a passenger on] a bicycle while

not wearing a protective bicycle helmet of good fit fastened securely upon the

head with the straps of the helmet, it would be your duty to return a verdict

of responsible. 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

responsible.