UJI 14-361 NMRA
UJI 14-361. Assault on a [school employee] [health care worker]; attempted battery with intent to commit a violent felony; essential elements.
For you to find the defendant guilty of aggravated assault on a
__________________1 with intent to [kill] [or]2 [commit ____________]3 [as charged in
Count ______],4 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 _______________________;5
A battery consists of intentionally touching or applying force in a rude, insolent or
angry manner.6
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;7
4. The defendant knew ____________ (name of victim) was a
_________________;1
5. The defendant also intended to [kill] [or]2 [commit __________________]3 on
__________________ (name of victim);
6. This happened in New Mexico on or about the ______ day of ____________,
_______.