Conn. Crim. Jury Instr. 8.1-3

The defendant is charged [in count__] with the illegal distribution of a controlled substance to a

minor. The statute defining this offense imposes penalties on any person eighteen years of age

or older who is not, at the time, a drug-dependent person,1 and who (distributes / sells / offers /

gives)2 any controlled substance to another person who is under eighteen years of age and is at

least two years younger than the defendant.

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

beyond a reasonable doubt:

Element 1 - Distributed a controlled substance

The first element is that the defendant (distributed / sold / offered / gave) a controlled substance,

specifically <insert specific substance>,

3 to another person.

Element 2 - Age of defendant

The second element is that the defendant was eighteen years of age or older at the time of the

alleged offense.

Element 3 - Age of other person

The third element is that at the time of the alleged offense the person to whom the <insert

specific substance> was (distributed / sold / offered / given) was under eighteen years of age and

at least two years younger than the defendant.

Conclusion

In summary, the state must prove beyond a reasonable doubt that 1) the defendant (distributed /

sold / offered / gave) <insert type of substance>, 2) the defendant was at least 18 years of age at

the time, and 3) the person to whom the <insert type of substance> was (distributed / sold /

offered / given) to was under the age of 18 and at least 2 years younger than the defendant.

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

of the crime of the distribution of a controlled substance, 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 Non-drug-dependency is not an element of the crime. See Affirmative Defense of Drug

Dependency, Instruction 8.1-4.

2 See Drug Transactions in the Introduction to this section.

3 See Defining the Controlled Substance in the Introduction to this section.