UJI 14-381 NMRA
UJI 14-381. Assault; attempted battery with intent to commit a violent felony; "household member"; essential elements.
For you to find the defendant guilty of assault with intent to [kill] [or]1 [commit
________________]2 [as charged in Count ______],3 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 ________________;4
A battery consists of intentionally touching or applying force in a rude, insolent or
angry manner.5
2. The defendant began to do an act which constituted a substantial part of the
battery but failed to commit the battery;
3. The defendant also intended to [kill] [or]1 [commit ________________]2 on
________________ (name of victim);
4. _________________ (name of victim) was a household member of the
defendant;6
5. This happened in New Mexico on or about the ________ day of _____________,
_____.