UJI 14-240B NMRA
UJI 14-240B. Homicide by vehicle; driving under the influence; essential elements.
For you to find the defendant guilty of causing death by driving under the influence
[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 drug5;]
2. The defendant’s driving while under the influence of [liquor]4 [or] [drugs] caused6
the death of ______________________________ (name of victim);
3. This happened in New Mexico on or about the _________ day of
______________, ________.