UJI 14-352 NMRA
UJI 14-352. Assault on a [school employee] [sports official] [health care worker]; threat or menacing conduct; 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 _________________ (describe unlawful act, threat or menacing
conduct);
2. The defendant’s conduct caused _________________ (name of victim) to
believe that the defendant was about to intrude on _________________’s (name of
victim) bodily integrity or personal safety by touching or applying force to
_________________ (name of victim) in a rude, insolent or angry manner3;
3. A reasonable person in the same circumstances as _________________ (name
of victim) would have had the same belief;
4. At the time, _________________ (name of victim) was a _________________1
and was performing duties of a __________________1;4
5. The defendant knew _________________ (name of victim) was a
_________________.1
6. This happened in New Mexico on or about the ______ day of ______________,
_______.