A person is guilty of aggravated reckless driving if, 1) either: a) the Defendant drives a vehicle recklessly in disregard of the rights or safety of others; or b) the Defendant drives a vehicle without due caution and circumspection and at a speed or in a manner so as to endanger or be likely to endanger any person or the property of another; and 2) by reason of the reckless driving, the defendant causes and inflicts injury upon another person.

ESSENTIAL ELEMENTS OF OFFENSE

The [City’s] [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 [City] [County], North Dakota, the Defendant, _______________,

2) [Drove a vehicle recklessly in disregard of the rights or safety of others] [Drove a vehicle without due caution and circumspection and at a speed or in a manner so as to endanger or be likely to endanger any person or the property of another]; and

3) By reason of the reckless driving, the Defendant caused and inflicted injury upon another person.

DEFINITIONS [Insert definitions from NDCC 12.1-02-02.]

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