Conn. Civ. Jury Instr. 3.11-5

The plaintiff in this case is seeking to recover damages for slander. Slander is oral defamation of

character. Slander is the speaking of defamatory words which injure the reputation of the person

defamed or which deter people from associating with or dealing with the person defamed.

In most cases, plaintiffs must prove actual injury to their reputations in order to recover in an

action for slander. Actual injury must be proven unless the slander occurred in one of the

categories called slander per se. If a statement is slanderous per se, plaintiffs are entitled to

recover for general damages to their reputations without having to prove that actual damage was

caused by the statements. This is because the law conclusively presumes that these statements

cause injury to a person’s reputation.

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

If you find that the plaintiff has proven, by a preponderance of the evidence, that the defendant

made the statement to a third person, which identified the plaintiff, such that it would be

reasonably understood that it was about the plaintiff, then this would be slander 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 someone with having a loathsome or contagious disease.

• it charges a woman with being unchaste.

• it charges someone with incompetence or dishonesty in office.

• it charges a professional person with general incompetence.

• it charges a person with conduct or characteristics that would adversely affect

that person’s trade or business.