Conn. Crim. Jury Instr. 6.11-11

Note: This instruction is for crimes committed on or after October 1, 2021.

The defendant is charged [in count__] with enticing a juvenile to commit a criminal act. The

statute defining this offense reads in pertinent part as follows:

A person is guilty of enticing a juvenile to commit a criminal act if such person is

twenty-three years of age or older and knowingly (causes / encourages / solicits /

recruits / intimidates / coerces) a person under eighteen years of age to commit or

participate in the commission of a criminal act.

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

beyond a reasonable doubt:

Element 1 - Twenty-three years of age

The first element is that the defendant was twenty-three years of age or older at the time of the

alleged offense. This means that the defendant had already reached his twenty-third birthday

when the conduct at issue is alleged to have taken place.

Element 2 - Enticed juvenile to commit or participate in criminal act

The second element is that the defendant (caused / encouraged / solicited / recruited / intimidated

/ coerced) a person under eighteen years of age to (commit / participate in the commission of) a

criminal act.

This means that the person whom the defendant (caused / encouraged / solicited / recruited /

intimidated / coerced) had not yet reached (his/her) eighteenth birthday when the conduct is

alleged to have taken place.

“Criminal act” means conduct constituting a felony or a misdemeanor, which are offenses for

which a person may be sentenced to a term of imprisonment.

1 <Insert alleged crime> is a

(felony / misdemeanor).

Element 3 - Knowingly

The third element is that the defendant knowingly (caused /encouraged / solicited / recruited /

intimidated / coerced) such person to (commit / participate in the commission of) a crime.

A person acts “knowingly” with respect to conduct or to a circumstance when (he/she) is aware

that (his/her) conduct is of such nature or that such circumstance exists. <See Knowledge,

Instruction 2.3-3.>

Conclusion

In summary, the state must prove beyond a reasonable doubt that 1) the defendant was twenty-three years of age or older, 2) the defendant (caused / encouraged / solicited / recruited /

intimidated / coerced) a person under eighteen years of age to (commit / participate in the

commission of) a criminal act, and 3) the defendant did so knowingly.

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

of the crime of enticing a juvenile to commit a criminal act, 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.

1 General Statutes § 53a-224 (a) (2).