Conn. Crim. Jury Instr. 2.5-6

New, June 13, 2008 (modified November 6, 2014)

Evidence has been introduced that the complaining witness,1 <insert name of complainant>, may

be culpable in the alleged offense. You must consider the credibility of <insert name of

complainant> in light of any motive (he/she) might have for testifying falsely and incriminating

the accused, <insert name of defendant>.

In evaluating the testimony of this witness, you should consider (his/her) appearance and

demeanor as a witness, the reasons given for (his/her) coming forward and telling (his/her) story

to the authorities, and whether any motive has appeared or any reason is apparent why (he/she)

would accuse the defendant.

You must consider and compare (his/her) testimony with all the other testimony and evidence in

the case. It is up to you to determine whether to believe this witness. Like all other questions of

credibility, this is a question you must decide based on all the evidence presented to you.

1 “A complaining witness or prosecuting witness is the person who was chiefly injured, in person

or property, by the act constituting the alleged crime . . . and who instigates [causes the

instigation of] the prosecution.” State v. Sinchak, 47 Conn. App. 134, 144 n.5 (1997), quoting

Black’s Law Dictionary (6th Ed. 1990).