SEQ CHAPTER \h \r 1CR06-141 11/09/07




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.