MUJI 2d CR1009

(DEFENDANT'S NAME) is charged [in Count ____] with

committing Negligently Operating a Vehicle Resulting in Injury [on or about

(DATE)]. You cannot convict [him] [her] of this offense unless, based on the

evidence, you find beyond a reasonable doubt each of the following elements:

[1. (DEFENDANT'S

NAME);

a. Operated a vehicle in a negligent manner; and

b. This negligence caused [serious] bodily injury to another; and

c. (DEFENDANT'S NAME):

i. [Had sufficient alcohol in [his] [her] body that a

subsequent chemical test showed that [he] [she] had a blood or breath alcohol

concentration of .05 grams or greater at the time of the test;]

ii. [Was under the influence of [alcohol] [a drug] [the combined

influence of alcohol and a drug] to a degree that rendered [him] [her]

incapable of safely operating a vehicle;] or

iii. [Had a blood or breath alcohol concentration of .05 grams or

greater at the time of operation;]]

OR

[2. (DEFENDANT'S

NAME);

a. Operated a vehicle

in a criminally negligent manner; and

b. This negligence caused [serious] bodily injury to another; and

c. Had in [his] [her] body any measurable amount

of a controlled substance.]

After you carefully consider all the evidence in this case,

if you are convinced that each and every element has been proven beyond a

reasonable doubt, then you must find the defendant GUILTY. On the other hand,

if you are not convinced that each and every element has been proven beyond a

reasonable doubt, then you must find the defendant NOT GUILTY.