UJI 14-3111 NMRA
UJI 14-3111. Controlled substance; trafficking by possession with intent to distribute; narcotic drug; essential elements.1
For you to find the defendant guilty of “trafficking a controlled substance by
possession with intent to distribute” [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 possessed4 a drug called __________________3 [4];
2. The defendant knew it was __________________3 [or believed it to be
__________________3]5 [or believed it to be some drug or other substance the
possession of which is regulated or prohibited by law];
3. The defendant intended to transfer it to another;
4. This happened in New Mexico on or about the __________ day of
______________, __________.