14-2227. Assault on a jail; essential elements.
For you to find the defendant guilty of assault on a jail [as charged in Count __________]1, the state must prove to your satisfaction beyond a reasonable doubt each of the following elements of the crime:
1. The defendant assaulted2 or attacked __________________,3 [a jail]4 [a prison] [place of confinement of prisoners];
2. This happened in New Mexico on or about the __________ day of ______________, __________.
USE NOTES
1. Insert the count number if more than one count is charged.
2. If the jury asks for a definition of "assaulted," use a non-law dictionary definition.
3. Identify the place of the attack.
4. Use only the applicable bracketed element established by the evidence.