Conn. Civ. Jury Instr. 3.11-4

Certain written defamatory statements are considered to be so harmful in and of themselves that

the person to whom they relate is entitled to recover general damages for injury to reputation,

without proving that any special or actual damages were caused by the statements. These

defamatory statements are called libel per se. Libel per se is a type of libel in which the

defamatory meaning is apparent on the face of the statement.

When the defamatory words are libel per se, the law conclusively presumes that there is injury to

the plaintiff’s reputation. Plaintiffs are not required to prove that their reputations were

damaged. Plaintiffs are entitled to recover, as general damages, for the injury to their reputations

and for the humiliation and mental suffering caused by the libel.

In this case, the plaintiff claims that <insert allegations>.

If you find that the plaintiff has proven each of the elements of libel, as I have previously

instructed you, then this would be libel per se because <insert as appropriate:>

• it charges one with a crime that is punishable by imprisonment.

• it charges one with a crime that involves moral turpitude, which is defined as an

act of inherent baseness, vileness or depravity.

• it charges one with improper conduct or lack of skill in a profession and is likely

to injure one in that profession or calling.