A person who willfully causes serious bodily injury to another human being is guilty of Aggravated Assault.
ESSENTIAL ELEMENTS OF OFFENSE
The State’s burden of proof is satisfied if the evidence shows, beyond a reasonable doubt, the following essential elements:
1) On or about [month] [day] [year], in [County], North Dakota, the Defendant, ____________, caused serious bodily injury to ______________, another human being, as follows: _____________; and
2) The Defendant willfully engaged in the conduct causing the injury[.] [; and]
[3) [_____________ was under the age of twelve years] [____________ suffered permanent loss or impairment of the function of a bodily member or organ].]
DEFINITIONS [Insert relevant definitions. NDCC 12.1-01-04, 12.1-02-02.] A “serious bodily injury” is defined as “bodily injury that creates a substantial risk of death or which causes serious permanent disfigurement, unconsciousness, extreme pain, permanent loss or impairment of the function of any bodily member or organ, a bone fracture, or impediment of air flow or blood flow to the brain or lungs.” NDCC 12.1-01-04(29).