UJI 14-231. Involuntary manslaughter; essential elements.1

For you to find the defendant guilty of involuntary manslaughter [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. __________________ (name of defendant) ______________________________ (describe defendant’s act); 2. ________________________ (name of defendant) should have known of the danger involved by ________________________’s (name of defendant) actions; 3. ________________________ (name of defendant) acted with a willful disregard for the safety of others; 4. ________________________’s (name of defendant) act caused the death of ________________________ (name of victim); 5. This happened in New Mexico on or about the ________ day of ______________, ________.