UJI 14-367 NMRA
UJI 14-367. Aggravated battery on a [school employee] [sports official] [health care worker] with a deadly weapon; essential elements.
For you to find the defendant guilty of aggravated battery on a ______________1
with a deadly weapon [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 touched or applied force to ________________ (name of victim)
by _________________________3 with a [________________]4 [deadly weapon. A
________________ (name of object) is a deadly weapon only if you find that a
________________ (name of object), when used as a weapon, could cause death or
great bodily harm5];6
2. At the time, ________________ (name of victim) was a ________________1 and
was performing the duties of a ________________1;7
3. The defendant knew ________________ (name of victim) was a
______________;1
4. The defendant intended8 to injure ________________ (name of victim);
5. This happened in New Mexico on or about the ____ day of ____________,
_____.