Conn. Crim. Jury Instr. 1.2-2

This is a criminal case. The state has brought charges against <insert name of defendant> as

follows: <read information>.

The information which I just read is not evidence. It is merely the formal means of accusing a

person of a crime and bringing (him/her) to trial. You must not consider it as any evidence of the

guilt of the defendant or draw any inference of guilt because the defendant has been arrested and

formally charged. Each charge against the defendant is set forth in the information as a separate

count, and you must consider each count separately in deciding this case.

<Identify each offense charged and summarize the elements.

1>

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1 When delivering the preliminary instructions, it is proper to identify the offenses and their

elements with reference to the overall language of the charged statute(s). Because the court, at

this juncture, has not yet had the benefit of seeing the evidence subsequently presented at trial, it

is not required to tailor the statutory language to be consistent with that evidence, as it must in

the final instructions. See State v. Tahir L., 227 Conn. App. 653, 660, 663-64 (trial court, in case

alleging fourth degree sexual assault, properly instructed jury preliminarily on full statutory

definition of “sexual contact” and entire intent element; in its final instructions, it omitted the

inapplicable portions of each, consistent with the evidence presented), cert. denied, 350 Conn.

913 (2024).