Conn. Crim. Jury Instr. 6.1-9

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 with intent to cause serious

physical injury to another person, (he/she) causes such injury to such person or to 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. 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.>

“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.”

Element 2 - Caused serious physical injury

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

to that person or to a third person. This means that the defendant’s conduct was the proximate

cause of <insert name of person injured>’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.>

[<If person injured was not the person intended:> It does not matter whether <insert name of

person injured> was the person upon whom the defendant intended to inflict serious physical

injury. It is sufficient if you find that the defendant intended to cause serious physical injury to

another person and that (he/she) in fact caused serious physical injury to that person or to some

other person.]

Conclusion

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

specific intent to cause serious physical injury to another person <insert name of person, if

applicable>, and 2) the defendant did cause serious 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.