Conn. Crim. Jury Instr. 2.1-2

It is exclusively the function of the court to state the rules of law that govern the case, with

instructions as to how you are to apply them. It is your obligation to accept the law as I state it.

You must follow all of my instructions and not single out some and ignore others; they are all

equally important.

You are the sole judge of the facts. It is your duty to find the facts. You are to recollect and

weigh the evidence and form your own conclusions as to what the ultimate facts are. You may

not go outside the evidence introduced in court to find the facts. This means that you may not

resort to guesswork, conjecture or suspicion, and you must not be influenced by any personal

likes or dislikes, opinions, prejudices or sympathy.

You should not be influenced by my actions during the trial in ruling on motions or objections by

counsel, or in comments to counsel, or in questions to witnesses, or in setting forth the law in

these instructions. You are not to take my actions as any indication of my opinion as to how you

should determine the issues of fact. If I asked any questions of a witness, you must not assume

that I hold any opinion on the matter to which my questions may relate. Remember that you, as

jurors, are at liberty to disregard all comments or questions of the court, and the witness’s

responses to those questions, in arriving at your own findings as to the facts. You must not take

anything I said or did during the trial as indicating what I think of the evidence or what your

verdict should be.

Any reference I make to the evidence is only for the purpose of clarification of some point of law

or a point of illustration or to refresh your recollection as to the general nature of the testimony.

I do not intend to emphasize any evidence I mention or limit your consideration to it. If I do not

mention certain evidence, you will use the evidence from your recollection. If my recollection of

the evidence does not comport with your recollection, then it is your recollection which must

prevail because you are the exclusive trier of the facts.

The defendant justly relies upon you to consider carefully (his/her) claims, to consider carefully

all of the evidence and to find (him/her) not guilty if the facts and the law require such a verdict.

The defendant rightfully expects fair and just treatment at your hands.

At the same time, the state of Connecticut and its people look to you to render a verdict of guilty

if the facts and law require such a verdict.

The law prohibits the state’s attorney or defense counsel from giving personal opinions as to

whether the defendant is guilty or not guilty. It is not their assessment of the credibility of

witnesses that matters, only yours.

1In State v. Mebane, 350 Conn. 483, 496-97 (2024), the Supreme Court urged trial courts to

exercise caution when posing questions directly to witnesses. When a court exercises its

discretion to do so, it should instruct the jury, consistent with this instruction, “that the court’s

questions to witnesses should not be taken by the jury as an indication of its opinion as to how

the jury should resolve any issues of fact.” Id., 499-500.

2 Do not include the following language: “The state as well does not want the conviction of an

innocent person. The state is as much concerned in having an innocent person acquitted as in

having a guilty person convicted.” State v. Carrion, 313 Conn. 823, 847-49 (2014) (using its

supervisory authority to direct trial courts to not include this language). This language has

repeatedly been criticized by the Appellate Court. Id., 848-49 n.17.