Conn. Crim. Jury Instr. 10.9-1

Note: The degree of the offense depends on the value of the slugs. See § 53a-144 (first

degree): exceeds $100; § 53a-145 (a) (2) (second degree): does not exceed $100.

The defendant is charged [in count__] with unlawfully using slugs in the first degree. The

statute defining this offense reads in pertinent part as follows:

a person is guilty of unlawfully using slugs in the first degree when (he/she) (makes /

possesses / disposes of) slugs with intent to enable a person to insert or deposit them

in a coin machine and the value of such slugs (exceeds / does not exceed) one

hundred dollars.

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

beyond a reasonable doubt:

Element 1 - Made, possessed or disposed of slugs

The first element is that the defendant (made / possessed / disposed of) slugs. “Slug” means an

object or article which, by virtue of its size, shape or any other quality, is capable of being

inserted or deposited in a coin machine as an improper substitute for a genuine coin, bill or

token. <See Possession, Instruction 2.11-1.>

Element 2 - Intent

The second element is that (he/she) (made / possessed / disposed of) slugs with the intent to

enable a person to insert or deposit them in a coin machine. “Coin machine” means a coin box,

turnstile, vending machine or other mechanical or electronic device or receptacle designed (A) to

receive a coin or bill or token made for the purpose, and (B) in return for the insertion or deposit

thereof, automatically to offer, to provide, to assist in providing or to permit the acquisition of

some property or some service.

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.>

Element 3 - Value

The third element is that the value of such slugs (exceeded / did not exceed) one hundred dollars.

“Value” of a slug means the value of the coin, bill or token for which it is capable of being

substituted.

Conclusion

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

possessed / disposed of) slugs, 2) (he/she) had the intent to enable a person to insert or deposit

them in a coin machine, and 3) the value of the slugs (exceeded / did not exceed) one hundred

dollars.

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

of the crime of unlawfully using slugs in the (first / second) degree, 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.