Conn. Crim. Jury Instr. 2.2-6

New, June 13, 2008 (modified April 23, 2010; March 22, 2023)

The defendant is charged with __ counts [in __ separate informations]. [<If there is more than

one information:> The state has commenced __ separate cases against the defendant. They have

been consolidated for the convenience of trial.]

[<If the information has been amended since beginning of trial:> To the extent that there have

been any changes regarding the content of the information[s], it is of no concern to your

deliberations. You are to consider only the specific charges submitted to you and not concern

yourself with how the information[s] may have read when it was read to you at the start of trial.]

The defendant is entitled to and must be given by you a separate and independent determination

of whether (he/she) is guilty or not guilty as to each of the counts. Each of the counts charged is

a separate crime. The state is required to prove each element in each count beyond a reasonable

doubt. Each count must be deliberated upon separately. The total number of counts charged

does not add to the strength of the state’s case.

You may find that some evidence applies to more than one count in more than one information.

The evidence, however, must be considered separately as to each element in each count. Each

count is a separate entity.

You must consider each count separately and return a separate verdict for each count. This

means that you may reach opposite verdicts on different counts. A decision on one count does

not bind your decision on another count.

1 When charges involve different victims, the jury must also be instructed to separately consider

the charges relating to each victim, and the evidence pertaining to each victim must be clearly

distinguished. State v. Davis, 286 Conn. 17, 33-36 nn.8-12 (2008); State v. Ellis, 270 Conn. 337,

378-79 (2004).