Conn. Crim. Jury Instr. 5.1-2

The defendant is charged [in count __] with manslaughter in the first degree. The statute

defining this offense reads in pertinent part as follows:

a person is guilty of manslaughter in the first degree when with intent to cause serious

physical injury to another person, (he/she) causes the death of such person or of a

third person.

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

beyond a reasonable doubt:

Element 1 - Intent to cause serious physical injury

The first element is that the defendant specifically intended to cause serious physical injury to

another person. “Serious physical injury” is something more serious than mere physical injury,

which is defined as “impairment of physical condition or pain.” It is more than a minor or

superficial injury. It is defined by statute as “physical injury which creates a substantial risk of

death, or which causes serious disfigurement, serious impairment of health or serious loss or

impairment of the function of any bodily organ.” You will note that the basis of the charge

under this statute is not that the defendant intended to kill, but that he intended to inflict serious

physical injury.

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.>

The intent to cause serious physical injury may be inferred from circumstantial evidence. <See

Evidence of Intent, Instruction 2.3-2.>

Element 2 - Caused death

The second element is that the defendant, acting with the intent to cause serious physical injury

to another person, caused the death of <insert name of decedent>.

[<If transferred intent is applicable:> It is not necessary for a conviction of intentional

manslaughter that the state prove that the defendant intended to kill the person whom (he/she)

did in fact kill. It is sufficient if the state proves that, acting with the intent to cause serious

physical injury to a person, (he/she) in fact killed a person.]

This means that the defendant’s conduct was the proximate cause of the decedent’s death. You

must find it proved beyond a reasonable doubt that <insert name of decedent> died as a result of

the actions of the defendant. <See Proximate Cause, Instruction 2.6-1.>

Conclusion

In summary, the state must prove beyond a reasonable doubt that 1) the defendant intended to

cause serious physical injury to another person, and 2) in accordance with that intent, the

defendant caused the death of <insert name of decedent>.

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

of the crime of manslaughter in the first degree, 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.