UJI 14-1615 NMRA
UJI 14-1615. Organized retail crime; agent.
For you to find ____________ (name of defendant) guilty of organized retail crime
[as charged in Count ___________]1, the state must prove to your satisfaction beyond a
reasonable doubt each of the following elements of the crime:
1. ____________ (name of defendant) and another person or persons had an
organized plan to steal merchandise from [a retailer2]3[retailers];
2. _____________ (name of defendant) acted under the direction, influence, or
control of another person or persons;
3. The aggregated retail market value4 of the merchandise stolen was two thousand
five hundred dollars ($2,500) or more;
4. This happened in New Mexico [on or about the ______________ day of
___________________, ____________]3 [within the span of one year, between the
______________ day of ______________, _______________ and the
__________________ day of ________________, ____________].