14-134. "Proximate cause"; defined.1
In addition to the other elements of the crime of __________________ (name of crime) as set forth in instruction number ________2, the state must also prove to your satisfaction beyond a reasonable doubt that:
1. __________________ (name of victim) was __________________ (describe injury or harm);
2. The injury or harm was the foreseeable result of the defendant's act; and
3. The act of the defendant was a significant cause of the injury or harm.
The defendant's act was a significant cause of the injury or harm if it was an act which, in a natural and continuous chain of events, uninterrupted by an outside event, resulted in the injury or harm and without which the injury or harm would not have occurred.
[There may be more than one significant cause of the injury or harm. If the acts of two or more persons significantly contribute to the cause of the injury or harm, each act is a significant cause of the injury or harm.]3
USE NOTES
1. This instruction should be used in cases in which causation is an issue. It is not to be used in homicide cases. See Instructions 14-251 and 14-252.
2. Insert here the number assigned by the court to the elements instruction for the named offense.
3. Use the bracketed language if there is evidence that the acts of more than one person contributed to the injury or harm to the victim.
[Approved, effective January 1, 2000.]