Conn. Crim. Jury Instr. 6.1-13

The defendant is charged [in count __] with assault in the second degree. The statute defining

this offense reads in pertinent part as follows:

a person is guilty of assault in the second degree when (he/she) is a parolee from a

correctional institution and with intent to cause physical injury to an employee or

member of the board of parole, (he/she) causes physical injury to such employee or

member.

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

beyond a reasonable doubt:

Element 1 - On parole

The first element is that the defendant was, at the time of the alleged offense, on parole from a

correctional institution. This means (he/she) was released from a correctional institution prior to

the expiration of (his/her) term of imprisonment but remains under the supervision of the board

of parole.

Element 2 - Intent to cause physical injury

The second element is that the defendant intended to cause physical injury to a person known by

the defendant to be an employee or member of the board of parole. 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.>

Element 3 - Caused physical injury

The third element is that the defendant in fact caused physical injury to an employee or member

of the board of parole. This means that the defendant’s conduct was the proximate cause of the

person’s injuries. You must find it proved beyond a reasonable doubt that <insert name of

person injured> was injured as a result of the actions of the defendant. <See Proximate Cause,

Instruction 2.6-1.>

“Physical injury” is defined as impairment of physical condition or pain. It is a reduced ability to

act as one would otherwise have acted. The law does not require that the injury be serious. It

may be minor.

Conclusion

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

from a correctional institution, 2) the defendant intended to cause physical injury to <insert name

of person injured>, whom (he/she) knew to be an employee or member of the board of parole,

and 3) the defendant caused physical injury to <insert name of person injured>.

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

of the crime of assault in the second 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.