Conn. Crim. Jury Instr. 10.7-5

New, November 6, 2014

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 state

marshal with intent to obtain a benefit or 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 by (his/her) words or conduct, pretended to be a state

marshal. 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 <insert as appropriate:>

• obtain a benefit.

• 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 a state marshal, and 2) intended to (obtain a benefit / 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 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, cert. denied, 237 Conn. 924 (1996).