Conn. Crim. Jury Instr. 7.5-7

The defendant is charged [in count__] with disseminating voyeuristic material. The statute

defining this offense reads in pertinent part as follows:

a person is guilty of disseminating voyeuristic material when such person

disseminates a photograph, film, videotape or other recorded image of another person

without the consent of such other person and knowing that such photograph, film,

videotape or image was taken, made or recorded in violation of our law prohibiting

voyeurism.

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

beyond a reasonable doubt:

Element 1- Dissemination

The first element is that the defendant disseminated a photograph, film, videotape or other

recorded image of another person. In this case, the state alleges that the defendant disseminated

a (photograph / film / videotape / recorded image) of <identify complainant>.

Element 2 - Without Consent

The second element is that the dissemination was done without the consent of such other person.

In this case, the state alleges that the defendant disseminated a (photograph / film / videotape /

recorded image) of <identify complainant> without (his/her) consent.

A person does an act without consent of another person when (he/she) lacks such other person’s

agreement or assent to engage in the act. Consent may be express or it may be implied from the

circumstances that you find existed at the time of the act. Consent must, however, have been

actual and not simply an acquiescence brought about by force, fear, threat or deception. The act

of consent must have been truly knowing and voluntary.

Element 3 - Knowingly voyeuristic

The third element is that the defendant knew that such (photograph / film / videotape / recorded

image) was (taken / made / recorded) in violation of our law prohibiting voyeurism. A person

acts “knowingly” with respect to a circumstance when (he/she) is aware that such circumstance

exists. <See Knowledge, Instruction 2.3-3>

Our law prohibits the crime of voyeurism. For an image to have been taken, made or recorded in

violation of our law:

<Insert appropriate elements of Voyeurism. See Voyeurism, Instruction 7.5-1, Voyeurism by

Trespass, Instruction 7.5-2, or Voyeurism (by filming under clothing), Instruction 7.5-3>

The state must prove that the defendant knew that such (photograph / film / videotape / image)

was (taken / made / recorded) in violation of our law. Ordinarily, knowledge can be established

only through an inference from other proven facts and circumstances. The inference may be

drawn if the circumstances are such that a reasonable person of honest intention, in the situation

of the defendant, would have concluded that such (photograph / film / videotape / image) was

(taken / made / recorded) in violation of our law. The determinative question is whether the

circumstances in the particular case form a basis for a sound inference as to the knowledge of the

defendant in the transaction under inquiry.

Conclusion

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

(photograph / film / videotape / recorded image) of <identify complainant>, 2) (he/she) did so

without the consent of <identify complainant> and 3) (he/she) did so knowing that such

(photograph / film / videotape / image) was (taken / made / recorded) in violation of our law.

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

of the crime of disseminating voyeuristic material, 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.