UJI 14-351 NMRA
UJI 14-351. Assault upon a [school employee] [health care worker]; attempted battery; essential elements.
For you to find the defendant guilty of an assault on a __________1 [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 intended to commit the crime of battery against
_______________ (name of victim) by ________________________;3
A battery consists of intentionally touching or applying force in a rude, insolent or
angry manner.4
2. The defendant began to do an act which constituted a substantial part of the
battery but failed to commit the battery;
3. At the time ___________________ (name of victim) was a _________________1
and was performing the duties of a ___________________1;5
4. The defendant knew ___________________ (name of victim) was a
__________________;1
5. This happened in New Mexico on or about the _______ day of ______________,
_______.