Conn. Crim. Jury Instr. 4.1-3

The defendant is charged [in count __] with bribery of a labor official. The statute defining this

offense reads in pertinent part as follows:

a person is guilty of bribery of a labor official if (he/she) (offers / confers upon /

agrees to confer upon) a labor official any benefit with intent to influence (him/her) in

respect to any of (his/her) acts, decisions or duties as such labor official.

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

beyond a reasonable doubt:

Element 1 - Benefit to a labor official

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

benefit upon a labor official. “Benefit” means 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. A “labor official” means any duly appointed or elected

representative of a labor organization or any duly appointed or elected trustee or representative

of an employee welfare trust fund.

Element 2 - Intent to influence

The second element is that in (offering / conferring upon / agreeing to confer upon) a benefit, the

defendant specifically intended to influence the labor official in respect to any of (his/her) acts,

decisions or duties as a labor official.

You must find that the state has proved beyond a reasonable doubt that the defendant acted with

the specific intent to influence the labor official in respect to any of (his/her) acts, decisions or

duties as such labor official. A person acts “intentionally” with respect to a result when (his/her)

conscious objective is to cause such result. <See Intent: Specific, Instruction 2.3-1.>

Conclusion

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

conferred upon / agreed to confer upon) a benefit upon a labor official, and 2) the defendant did

so with the intent to influence the labor official in respect to any of (his/her) acts, decisions or

duties as a labor official.

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

of the crime of bribery of a labor official, 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.