Conn. Crim. Jury Instr. 6.6-1

The defendant is charged [in count__] with custodial interference in the first degree. The statute

defining this offense reads in pertinent part as follows:

a person is guilty of custodial interference in the first degree when (he/she) commits

custodial interference in the second degree <insert appropriate subsection:>

• § 53a-97 (a) (1): under circumstances which expose the (child / person) (taken or enticed

from lawful custody / held after a request by the lawful custodian) for (his/her) return to a

risk that (his/her) (safety will be endangered / health materially impaired).

• § 53a-97 (a) (2): by taking, enticing, or detaining the (child / person) out of this state.

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

beyond a reasonable doubt:

Element 1 - Committed custodial interference

The first element is that the defendant committed custodial interference in the second degree.

<Insert instruction for underlying crime:>

• § 53a-98 (a) (1): Custodial Interference in the Second Degree, Instruction 6.6-2.

• § 53a-98 (a) (2): Custodial Interference in the Second Degree, Instruction 6.6-3.

• § 53a-98 (a) (2): Custodial Interference in the Second Degree, Instruction 6.6-4.

Element 2 - Risk factor

The second element is that the defendant committed this offense <insert as appropriate:>

• under circumstances that exposed <insert name of child or person taken> to a risk that

(his/her) (safety would be endangered / health materially impaired).

• by taking, enticing or detaining <insert name of child or person taken> out of this state.

Conclusion

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

summary from the instruction for the underlying crime>, and that the <insert name of child or

person taken> was (exposed to a risk of <insert type of risk> / taken, enticed, or detained out of

this state).

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

of the crime of custodial interference 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.