Va. Model Jury Instr. Crim. No. 32.100

The defendant is charged with the crime of leaving the scene of an accident causing [personal

injury; death; damage to an attended vehicle; damage to attended property] [to; of] another. The

Commonwealth must prove beyond a reasonable doubt each of the following elements of that

crime:

(1) That the defendant was the driver of a vehicle which he knew was involved in an accident; and

(2) That the accident caused [personal injury; death; damage to an attended vehicle or other attended

property of more than $1000] [to; of] another; and

(3) That the defendant knew, or should have known, [that another person was injured by the accident;

that another person was killed in the accident; that an attended vehicle or other attended property was

damaged by the accident]; and

(4) That the defendant failed to do any of the following:

(a) stop immediately as close to the scene of the accident as possible without obstructing traffic;

or

(b) render reasonable assistance to any person injured in the accident; or

(c) report his name, address, driver’s license number and vehicle registration number forthwith to

the State Police or local law enforcement agency, or to the person struck and injured if such

person appeared to be capable of understanding and retaining the information, or to the driver or

some other occupant of the vehicle collided with or the custodian of other damaged property.

If you find from the evidence that the Commonwealth has proved beyond a reasonable doubt

each of the elements of the crime as charged, then you shall find the defendant guilty [but you

shall not fix the punishment until your verdict has been returned and further evidence has been

heard by you].

If you find that the Commonwealth has failed to prove beyond a reasonable doubt any one or

more of the elements of the crime, then you shall find the defendant not guilty.