UJI 14-240D NMRA
UJI 14-240D. Great bodily injury by vehicle; essential elements.
For you to find the defendant guilty of causing great bodily injury1 by vehicle [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 operated a motor vehicle3
[while under the influence of intoxicating liquor4]5 [or]
[while under the influence of _______________________, a drug]6 [or]
[in a reckless manner];7
2. The defendant’s [driving while under the influence of [liquor]5 [or] [drugs]] [or]
[reckless driving] caused8 the great bodily injury1 to
______________________________ (name of victim);
3. This happened in New Mexico on or about the _________ day of
______________, ________.