Conn. Crim. Jury Instr. 4.5-5

The defendant is charged [in count__] with bribery of a juror. The statute defining this offense

reads in pertinent part as follows:

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

upon a juror any benefit as consideration for the juror’s decision or vote.

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

beyond a reasonable doubt:

Element 1 - Benefit offered

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

<insert name of target of bribe>. “Benefit” means monetary advantage, or anything regarded by

the beneficiary as a monetary advantage, including a benefit to any person or entity in whose

welfare the beneficiary is interested.

Element 2 - To juror

The second element is that at the time the benefit was (offered / conferred / agreed to be

conferred), <insert name of target of bribe> was then a juror. A “juror” is any person who has

been drawn or summoned to serve or act as a juror in any court. In this case the state alleges that

the benefit involves <insert alleged benefit>.

Element 3 - As consideration for vote

The third element is that the benefit was consideration for the juror’s decision or vote. This

means that the defendant must have specifically intended that the benefit offered was in

exchange for the juror’s decision or vote. 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 / agreed to confer) a benefit upon <insert name of target of bribe>, 2) <insert name of

target of bribe> was then a juror, and 3) the defendant and <insert name of target of bribe> both

intended that the benefit would influence the juror’s decision or vote.

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

of the crime of bribery of a juror, 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.