Conn. Crim. Jury Instr. 10.2-17

The defendant is charged [in count__] with receiving money, goods or services obtained by the

illegal use of a payment card. The statute defining this offense imposes punishment on

any person who receives money, goods, services or anything else of value obtained

through the illegal use of a payment card, knowing or believing the same to have been

so obtained.

For you to find the defendant guilty of this charge, the state must prove the following elements

beyond a reasonable doubt:

Element 1 - Received money, goods or services

The first element is that the defendant received money, goods, services or anything else of value

obtained by the illegal use of a payment card.

1 <See Illegal Use of a Payment Card, Instruction

10.2-10, Illegal Use of a Payment Card, Instruction 10.2-11, and Illegal Use of a Payment Card,

Instruction 10.2-12.>

Element 2 - Knowledge

The second element is that the defendant knew or believed that the money, goods, services or

anything else of value had been obtained by the illegal use of a payment card. A person acts

“knowingly” with respect to conduct or circumstances when (he/she) is aware that (his/her)

conduct is of such nature or that such circumstances exist. <See Knowledge, Instruction 2.3-3.>

[<Include if appropriate:> Any person who obtains at a discount price a ticket issued by an

airline, railroad, steamship or other transportation company that was acquired by the illegal use

of a payment card without reasonable inquiry to ascertain that the person from whom it was

obtained had a legal right to possess it shall be presumed to know that such ticket was acquired

under circumstances constituting a violation of said section. This means that you may find, but

are not required to, that the defendant knew that the ticket had been acquired through the illegal

use of a payment card if you find that (he/she) did not make a reasonable inquiry into the

person’s right to use the card.]

Conclusion

In summary, the state must prove beyond a reasonable doubt that 1) the defendant received

money, goods, services or anything else of value obtained by the illegal use of a payment card,

and 2) (he/she) knew that the money, goods, services had been obtained by the illegal use of a

payment card.

If you unanimously find that the state has proved beyond a reasonable doubt each of the elements

of the crime of the receipt of money, goods, or services obtained by illegal use of a payment

card, then you shall find the defendant guilty. On the other hand, if you unanimously find that

the state has failed to prove beyond a reasonable doubt any of the elements, you shall then find

the defendant not guilty.

1 In violation of General Statutes § 53a-128d.