UJI 14-330 NMRA
UJI 14-330. Harassment; essential elements.
For you to find the defendant guilty of harassment 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 maliciously pursued a pattern of conduct that was intended to
[annoy] [seriously alarm] [or] [terrorize]2 ______________________________ (name of
victim);
2. A reasonable person would have suffered substantial emotional distress as a
result of the defendant’s actions;
3. The defendant’s conduct served no lawful purpose;
4. This happened in New Mexico on or about the ______________ day of
________________________, ________.