14-231. Involuntary manslaughter; essential elements.1
For you to find the defendant guilty of involuntary manslaughter [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. __________________ (name of defendant) ______________________________ (describe defendant's act);
2. ________________________ (name of defendant) should have known of the danger involved by ________________________'s (name of defendant) actions;
3. ________________________ (name of defendant) acted with a willful disregard for the safety of others;
4. ________________________'s (name of defendant) act caused the death of ________________________ (name of victim);
5. This happened in New Mexico on or about the ________ day of ______________, ________.
USE NOTES
1. This instruction is used in all involuntary manslaughter prosecutions.
2. Insert the count number if more than one count is charged.
[As amended, effective August 1, 1997.]