Idaho Aggravated Battery
In order for the defendant to be guilty of Aggravated Battery, the state must prove each of the following:
- On or about [date]
- in the state of Idaho
- the defendant [name] committed a battery upon [name of victim],
- by [description of conduct alleged in the charging document], and
- when doing so the defendant [caused great bodily harm, permanent disability, or permanent disfigurement] [or] [used a deadly weapon or instrument] [or] [used any vitriol, corrosive acid, or a caustic chemical of any nature] [or] [used any poison or other noxious or destructive substance or liquid] [or] [caused great bodily harm, permanent disability, or permanent disfigurement to an embryo or fetus].
An aggravated battery is punishable by imprisonment in the state prison not to exceed fifteen (15) years.