UJI 14-2228B. Escape; penitentiary release program; essential elements.1

For you to find the defendant guilty of escape from a penitentiary 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 defendant was released from __________________ (identify institution) to __________________ (describe purpose for release); 3. The defendant failed to return to confinement within the time fixed for the defendant’s return; 4. The defendant’s failure to return was willful, without sufficient justification or excuse;3 5. The defendant intended not to return within the time fixed;3 6. This happened in New Mexico on or about the __________ day of ______________, ________.