CR06-141 11/09/07
RECKLESSLY
The State must have proven that (Def)_______________ acted recklessly. You may find that (Def)_______________
acted recklessly if [he] [she] acted without regard to the possible
consequences of [his] [her] actions. In
other words, (Def)_______________ recklessly caused
(alleged harm)_______________ if [he] [she] consciously ignored a known,
substantial and unjustifiable risk that [his] [her] conduct would cause that
result. [His] [Her] disregard of the risk, when considered in light of the
nature and purpose of [his] [her] conduct, and the circumstances known to [him]
[her], must have been a gross deviation from how a law-abiding person would have acted in the same situation.