Conn. Crim. Jury Instr. 6.3-1

The defendant is charged [in count__] with reckless endangerment in the first degree. The

statute defining this offense reads in pertinent part as follows:

a person is guilty of reckless endangerment in the first degree when, with extreme

indifference to human life, (he/she) recklessly engages in conduct which creates a risk

of serious physical injury to 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 - With extreme indifference to human life

The first element is that the defendant acted with extreme indifference to human life.

“Indifference” means simply not caring. It means lacking any interest in a matter one way or the

other. Extreme means existing in the highest or greatest possible degree. Extreme indifference

is more than ordinary indifference. It is synonymous with excessive and is the greatest departure

from the ordinary. What evinces an extreme indifference to human life is a question of fact.

Element 2 - Acted recklessly

The second element is that the defendant acted recklessly. A person acts “recklessly” with

respect to a result or circumstances when (he/she) is aware of and consciously disregards a

substantial and unjustifiable risk that such result will occur or that such circumstances exist.

<See Recklessness, Instruction 2.3-4.>

Element 3 - Created risk of serious physical injury

The third element is that the defendant’s recklessness created a risk of causing 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.” It is unnecessary for any person to have been

injured by the defendant’s conduct or for the defendant to have intended to injure or endanger

any person.

Conclusion

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

extreme indifference to human life, 2) the defendant’s conduct was reckless, and 3) the defendant

posed a risk of causing serious physical injury to another person.

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

of the crime of reckless endangerment 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.