Conn. Crim. Jury Instr. 4.1-4

The defendant is charged [in count __] with bribe receiving by a labor official. The statute

defining this offense reads in pertinent part as follows:

a labor official is guilty of bribe receiving by a labor official if (he/she) (solicits /

accepts / agrees to accept) any benefit from another person upon an agreement or

understanding that such benefit will 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 - Labor official

The first element is that the defendant was a labor official within the meaning of that term, on the

dates alleged. “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 - Benefit sought

The second element is that the defendant (solicited / accepted / agreed to accept) a benefit of

<insert benefit> from <insert alleged provider of bribe>. “Benefit” means monetary advantage

or anything regarded by the beneficiary as monetary advantage, including a benefit to any person

or entity in whose welfare the beneficiary is interested.

Element 3 - Intent to influence

The third element is that the defendant (solicited / accepted / agreed to accept) that benefit upon

the understanding that such benefit would influence (him/her) 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 (solicited /

accepted / agreed to accept) the benefit with the specific intent that the receipt of the benefit

would influence (his/her) acts, decisions or duties. 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 was a labor

official on the dates alleged, 2) the defendant (solicited / accepted / agreed to accept) a benefit of

<insert benefit> from <insert alleged provider of bribe>, and 3) the defendant (solicited /

accepted / agreed to accept) that benefit upon the understanding that such benefit would

influence (him/her) 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 bribe receiving by 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.