2
3
Approved 5/5/82
CAUSING WIDESPREAD INJURY OR DAMAGE
(N.J.S.A. 2C:17-2b)
The defendant is charged with causing widespread injury or damage.
Our law provides in pertinent part:
"A person who recklessly causes widespread injury or damage is guilty of a crime....."
In order for you to find the defendant guilty of this crime the State must prove each of the following elements beyond a reasonable doubt.
1. That the defendant recklessly caused widespread injury or damage.
A person acts recklessly with respect to a material element of an offense when (he/she) consciously disregards a substantial and unjustifiable risk that the material element exists or will result from (his/her) conduct. The risk must be of such a nature and degree that, considering the nature and purpose of the actor's conduct and the circumstance known to (him/her) its disregard involves a gross deviation from the standard of conduct that a reasonable person would observe in the actor's situation.
You must find that the defendant's conduct did, in fact, cause the widespread injury or damage. That is, the actual result, in this case widespread injury or damage, must be within the risk of which the actor is aware. Should you find the result too remote, accidental or too dependent on another person's volitional act in its occurrence, then the defendant did not legally cause the result.
1
Widespread injury or damage means serious bodily injury to ten or more people or damage to ten or more habitations or to a building which would normally have contained fifty or more persons at the time of the offense.
2
Serious bodily injury means bodily harm which creates a substantial risk of death or which causes serious, permanent disfigurement or protracted loss or impairment of the function of any bodily member or organ.
3
If you find that the State has proven beyond a reasonable doubt each element of the crime of causing widespread injury or damage, you must find the defendant guilty.
1 N.J.S.A. 2C:2-3c.
N.J.S.A. 2C:17-2e.
N.J.S.A. 2C:3-11d.

CAUSING WIDESPREAD INJURY OR DAMAGE
(N.J.S.A. 2C:17-2b)
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If, however, you determine that the State has failed to prove one or more of the elements of the crime beyond a reasonable doubt, you must find the defendant not guilty.