UJI 14-362 NMRA
UJI 14-362. Assault on a [school employee] [health care worker]; threat or menacing conduct 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 [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. At the time, __________________ (name of victim) was a
__________________1 and was performing duties of a __________________1 4;
3. The defendant knew __________________ (name of victim) was a
__________________;1
4. 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 manner;3
5. A reasonable person in the same circumstances as __________________
(name of victim) would have had the same belief;
6. The defendant intended to kill __________________ (name of victim);
7. This happened in New Mexico on or about the ____ day of ____________,
_____.