Conn. Crim. Jury Instr. 5.1-6

The defendant is charged [in count __] with criminally negligent homicide. The statute

defining this offense reads in pertinent part as follows:

a person is guilty of criminally negligent homicide when, with criminal negligence,

(he/she) causes the death of another person.

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

beyond a reasonable doubt:

Element 1 - Cause of death

The first element is that the defendant caused the death of <insert name of decedent>. This

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

find proven 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.>

Element 2 - Criminal negligence

The second element is that the defendant was criminally negligent in causing the death. <See

Criminal Negligence, Instruction 2.3-5.>

Conclusion

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

death of <insert name of decedent>, and 2) the defendant was criminally negligent when (he/she)

caused the death.

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

of the crime of criminally negligent homicide, 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.