CRIMINAL PROPERTY DAMAGE IN THE FIRST DEGREE – DANGER OF DEATH OR BODILY INJURY

CRIMINAL PROPERTY DAMAGE IN THE FIRST DEGREE – DANGER OF DEATH OR BODILY INJURY: H.R.S. § 708-820(1)(a) (Applicable to offenses occurring on or after June 9, 2006) [In Count (count number) of the Indictment/Complaint, the] [The] Defendant, (defendant’s name), is charged with the offense of Criminal Property Damage in the First Degree. A person commits the offense of Criminal Property Damage in the First Degree if by means other than fire, he/she intentionally or knowingly damages property and thereby recklessly places another person in danger of death or bodily injury. There are three material elements of the offense of Criminal Property Damage in the First Degree, each of which the prosecution must prove beyond a reasonable doubt. These three elements are: 1. That, on or about (date) in the [City and] County of (name of county), by means other than fire, the Defendant damaged the property; and 2. That the Defendant did so intentionally or knowingly; and 3. That such conduct recklessly placed another person in danger of death or bodily injury. Notes H.R.S. §§ 708-820(1)(a), 702-206(1), (2), and (3). For definition of states of mind, see instructions: For definition of terms defined by H.R.S. Chapter 708, see instruction: For definition of terms not defined by H.R.S. Chapter 708, see instruction: