The state accuses the defendant of having committed the offense of failure to stop and render aid.

Relevant Statutes

A person commits the offense of failure to stop and render aid if—

1. the person operated a vehicle that was involved in an accident; and
2. the person knew he was involved in an accident; and
3. the person knew—
   1. the accident resulted in injury to or death of a person, or
   2. the accident was reasonably likely to have resulted in injury to or death of a person; and
4. the person did not— [insert specifics, e.g.,
   1. immediately return to the scene of the accident;
   2. immediately determine whether a person was involved in the accident and, if a person was involved in the accident, whether that person required aid;
   3. remain at the scene of the accident until the person had given his name to any person injured or the operator or occupant of or a person attending a vehicle involved in the collision;
   4. remain at the scene of the accident until the person had given his address to any person injured or the operator or occupant of or a person attending a vehicle involved in the collision;
   5. remain at the scene of the accident until the person had given the registration number of the vehicle he was driving to any person injured or the operator or occupant of or a person attending a vehicle involved in the collision;
   6. remain at the scene of the accident until the person had given the name of his motor vehicle liability insurer to any person injured or the operator or occupant of or a person attending a vehicle involved in the collision; or
   7. remain at the scene of the accident until the person had rendered reasonable assistance to another person when it was then apparent that another person was in need of medical treatment]; and
5. the accident resulted in [bodily injury/serious bodily injury/death] to another person.

Definitions

Knew He Was Involved in an Accident

A person knows the vehicle the person operated was involved in an accident if the person is aware that the vehicle was involved in an accident.

Knew the Accident Resulted in Injury to or Death of a Person

A person knows an accident resulted in injury to or death of a person if the person is aware that the accident resulted in injury or death.

Knew the Accident Was Reasonably Likely to Have Resulted in Injury to or Death of a Person

A person knows an accident was reasonably likely to have resulted in injury to or death of a person if the person is aware that the accident was reasonably likely to have resulted in injury or death.

Injury or Bodily Injury

“Injury” or “bodily injury” means physical pain, illness, or any impairment of physical condition.

Serious Bodily Injury

“Serious bodily injury” means bodily injury that creates a substantial risk of death or that causes death, serious permanent disfigurement, or protracted loss or impairment of the function of any bodily member or organ.

Application of Law to Facts

You must determine whether the state has proved, beyond a reasonable doubt, five elements. The elements are that—

1. the defendant, in [county] County, Texas, on or about [date], operated a vehicle that was involved in an accident; and
2. the defendant knew he was involved in an accident; and
3. the defendant knew—
   1. the accident resulted in injury to or death of a person, or
   2. the accident was reasonably likely to have resulted in injury to or death of a person; and
4. the defendant did not— [insert specific allegations, e.g.,
   1. immediately return to the scene of the accident;
   2. immediately determine whether a person was involved in the accident and, if a person was involved in the accident, whether that person required aid;
   3. remain at the scene of the accident until the defendant had given the defendant’s name to [name], the [person injured/operator of the vehicle/occupant of the vehicle/person attending the vehicle];
   4. remain at the scene of the accident until the defendant had given the defendant’s address to [name], the [person injured/operator of the vehicle/occupant of the vehicle/person attending the vehicle];
   5. remain at the scene of the accident until the defendant had given the registration number of the vehicle the defendant was driving to [name], the [person injured/operator of the vehicle/occupant of the vehicle/person attending the vehicle];
   6. remain at the scene of the accident until the defendant had given the name of the defendant’s motor vehicle liability insurer to [name], the [person injured/operator of the vehicle/occupant of the vehicle/person attending the vehicle]; or
   7. remain at the scene of the accident until the defendant had rendered reasonable assistance to [name] when it was then apparent that [name] was in need of medical treatment]; and
5. the accident resulted in [bodily injury/serious bodily injury/death] to [name].

You must all agree on elements 1, 2, 3, 4, and 5 listed above. You do not have to agree on whether element 3 is proven by 3.a or 3.b. You do not have to agree on whether element 4 is proven by 4.a, 4.b, 4.c, 4.d, 4.e, 4.f, or 4.g.

If you all agree the state has failed to prove, beyond a reasonable doubt, one or more of the elements listed above, you must find the defendant “not guilty.”

If you all agree the state has proved, beyond a reasonable doubt, all of the elements listed above, you must find the defendant “guilty.”

[Insert any other instructions raised by the evidence. Then continue with the verdict form found in CPJC 2.1, the general charge.]