Conn. Crim. Jury Instr. 10.7-2

The defendant is charged [in count__] with criminal impersonation. The statute defining this

offense reads in pertinent part as follows:

a person is guilty of criminal impersonation when (he/she) pretends to be a public

servant other than a sworn member of an organized local police department or the

division of state police within the department of emergency services and public

protection, or wears or displays without authority any uniform, badge or shield by

which such public servant is lawfully distinguished, with intent to induce another to

submit to such pretended official authority or otherwise to act in reliance upon that

pretense.

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

beyond a reasonable doubt:

Element 1 - Impersonation

The first element is that the defendant <insert as appropriate:>

• by (his/her) words or conduct, pretended to be a public servant other than a sworn

member of an organized local police department or the division of state police within the

department of emergency services and public protection.

• wore or displayed without authority a uniform, badge or shield by which a public servant

is lawfully distinguished.

A “public servant” is an officer or employee of government or a quasi-public agency, elected or

appointed, and any person otherwise paid or unpaid, in performing a governmental function.

To “pretend” means to make-believe, to feign, or to conduct a sham.

Element 2 - Intent

The second element is that by such action, (he/she) intended to induce another to submit to such

pretended official authority or otherwise to act in reliance upon such pretended authority. A

person acts “intentionally” with respect to a result when (his/her) conscious objective is to cause

such result. <See Intent: Specific, Instruction 2.3-1.>

Conclusion

In summary, the state must prove beyond a reasonable doubt that the defendant 1) (pretended to

be <insert type of public servant> / wore or displayed <insert allegations>), and 2) intended to

induce another to submit to such pretended official authority or otherwise to act in reliance upon

such pretended authority.

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

of the crime of criminal impersonation, 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 State v. Wall, 40 Conn. App. 643, 670-71 (distinguishing the intent to pretend from the intent to

induce another to submit to the pretended authority), cert. denied, 237 Conn. 924 (1996).