SEQ CHAPTER \h \r 1CR06-001 06/23/08

 

PROOF OF INTENT OR MENTAL STATE

The [intent] [mental state] with which a person does an act may be shown by the way in which he or she expresses it to others, or by his or her conduct.  In determining (Def)_______________’s [intent] [mental state], you should consider all of the surrounding facts and circumstances established by the evidence.