Conn. Crim. Jury Instr. 4.1-1

The defendant is charged [in count __] with bribery. The statute defining this offense reads in

pertinent part as follows:

a person is guilty of bribery if (he/she) (promises / offers / confers / agrees to confer)

upon a (public servant / a person selected to be a public servant), any benefit as

consideration for the recipient’s (decision / opinion / recommendation / vote) as a

(public servant / a person selected to be a public servant).

The essence of the crime of bribery is the voluntary giving of something of monetary value to a

(public servant / a person selected to be a public servant) to influence the performance of official

duty.

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

beyond a reasonable doubt:

Element 1 - Benefit

The first element is that the defendant (promised / offered / conferred / agreed to confer) a

benefit. “Benefit” means a monetary advantage, or anything regarded by the beneficiary as a

monetary advantage, including benefit to any person or entity in whose welfare the beneficiary is

interested.

Element 2 - To public servant

The second element is that at the time that the benefit was (promised / offered / conferred /

agreed to be conferred), the person who was to receive that benefit was a (public servant /

selected to be a public servant). <Insert the applicable definitions:>

• A “public servant” is an officer or employee of government or a quasi-public agency,

elected or appointed, and any person participating as adviser, consultant or otherwise,

paid or unpaid, in performing a governmental function.

• A “person selected to be a public servant” means any person who has been nominated or

appointed to be a public servant.

Element 3 - For consideration

The third element is that the benefit was consideration for the recipient’s (decision / opinion /

recommendation / vote) as a (public servant / person selected to be a public servant). In this case

the state alleges that the benefit was <identify the benefit>.

Conclusion

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

offered / conferred / agreed to confer) a benefit, 2) to a public servant, and 3) in consideration for

the recipient’s (decision / opinion / recommendation / vote) as a (public servant / person selected

to be a public servant).

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

of the crime of bribery, 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.