UJI 14-240A NMRA
UJI 14-240A. Injury to pregnant woman by vehicle; essential elements.
For you to find the defendant guilty of causing injury to a pregnant woman by vehicle
[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.
The defendant operated a motor vehicle2
[while under the influence of intoxicating liquor3];4
[while under the influence of ________, a drug];5
[in a reckless manner];6
2.
The defendant thereby caused7 __________________ (name of victim) to
suffer a [miscarriage8]4 [or] [stillbirth8].
3.
This happened in New Mexico on or about the ________ day of
______________, ________.