Conn. Crim. Jury Instr. 6.5-1

The defendant is charged [in count__] with kidnapping in the first degree. The statute defining

this offense reads in pertinent part as follows:

a person is guilty of kidnapping in the first degree when (he/she) abducts another

person and (his/her) intent is to compel a third person <insert as appropriate:>

• to pay or deliver money or property as ransom.

• to engage in particular conduct or to refrain from engaging in particular conduct.

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

beyond a reasonable doubt:

Element 1 - Abducted another person

The first element is that the defendant abducted another person. <Insert the elements from

Kidnapping in the Second Degree, Instruction 6.5-3.>

Element 2 - Intent

The second element is that the defendant abducted <insert name of abducted person> with the

specific intent to compel a third person to (pay money or property as ransom / do or refrain from

doing some particular thing). 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.>

You must find that the defendant abducted <insert name of abducted person> with the specific

intent to compel some other person to (pay money or property as ransom for the person’s release

/ do or refrain from doing some particular thing). There is no requirement that the defendant

communicate in any way with the third person whose (payment / action or inaction) is sought, or

specifically make any demand of that person, but merely that the defendant intends, by (his/her)

act, to compel the (payment / action or inaction).

Conclusion

In summary, the state must prove beyond a reasonable doubt that <insert the concluding

summary from the instruction for kidnapping in the second degree>, and that (he/she) intended to

compel a third person to (pay money or property as ransom / do or refrain from doing

something).

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

of the crime of kidnapping 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.

1 Second degree kidnapping is simple abduction. See General Statutes § 53a-94.