Conn. Civ. Jury Instr. 3.4-4

In addition to seeking compensatory damages, the plaintiff seeks an award of common law

punitive damages. Punitive damages may be awarded for conduct that demonstrates a reckless

indifference to the rights of others or an intentional and wanton violation of those rights. If the

plaintiff establishes that the defendant was recklessly indifferent to the rights of the plaintiff,

then the plaintiff need not prove that the defendant actually intended to do harm to the plaintiff.

If you find that the plaintiff has met the plaintiff’s burden to prove that the defendant’s conduct

demonstrates a reckless indifference to the rights of others or an intentional and wanton violation

of those rights, then you may award punitive damages. The law does not require you to award

punitive damages. It is, instead, a matter for your discretion.

Punitive damages are limited to the costs of litigation, including attorney’s fees, less taxable

costs. The plaintiff bears the burden of proving what those fees and taxable costs are. The

amount you chose to award is up to you, provided the plaintiff proves those amounts, and

provided you limit the award to the costs of litigation, including attorney’s fees, less taxable

costs.