Conn. Crim. Jury Instr. 10.9-2

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

statute defining this offense reads in pertinent part as follows:

a person is guilty of unlawfully using slugs in the second degree when, with intent to

defraud the owner of a coin machine, (he/she) inserts or deposits a slug in such

machine.

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

beyond a reasonable doubt:

Element 1 - Inserted or deposited slugs

The first element is that the defendant inserted or deposited a slug in a coin machine. “Coin

machine” means a coin box, turnstile, vending machine or other mechanical or electronic device

or receptacle designed to receive a coin or a bill or a token made for the purpose and, 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 “slug” means an object or article

that, 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.

Element 2 - Intent

The second element is that the defendant intended to defraud the owner of the coin machine.

<See Intent to Defraud, Instruction 2.3-6.>

Conclusion

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

deposited a slug in a coin machine, and 2) (he/she) had the intent to defraud the owner of the

coin machine.

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 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.