UJI 14-2228A. Escape; jail release program; essential elements.1

For you to find the defendant guilty of escape from a jail release program [as charged in Count ____________]2, the state must prove to your satisfaction beyond a reasonable doubt each of the following elements of the crime: 1. The defendant was committed to __________________ (identify institution); 2. The [sheriff] [jail administrator]3 of __________________ (identify institution), with the approval of the [board of county commissioners of __________________ (name of county)] [governing body of __________________ (name of municipality)] had established a release program to allow prisoners to [attend school] [or] [be employed]; 3. The defendant was released from __________________ (identify institution) to __________________ (describe purpose for release); 4. The defendant failed to return to confinement within the time fixed for the defendant’s return; 5. The defendant’s failure to return was willful, without sufficient justification or excuse;4 6. The defendant intended not to return within the time fixed;4 7. This happened in New Mexico on or about the __________ day of ______________, ________.