Conn. Crim. Jury Instr. 8.2-38

The defendant is charged [in count__] with the sale or delivery of body armor. The statute

defining this offense reads in pertinent part as follows:

no person, firm or corporation shall sell or deliver body armor to another person

unless the transferee meets in person with the transferor to accomplish the sale or

delivery and possesses a [state] permit or certificate.

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

beyond a reasonable doubt:

Element 1 - Sold or delivered body armor

The first element is that the defendant sold or delivered body armor to another person. The

words “sold” and “delivered” have their ordinary meaning. “Body armor” means any item

designed to provide bullet penetration resistance and to be worn on or under clothing on the

body, like a vest or other article of clothing.

Element 2 - Transfer not made in person or transferee lacked permit or certificate

The second element is that <insert as applicable:>

• the transfer of the body armor was not made in person; or

• the person to whom the body armor was transferred did not possess an authorizing permit

or certificate issued by the state of Connecticut.

Conclusion

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

delivered body armor to another person, and 2) (the transfer of the body armor was not made in

person / the other person did not possess the required permit or certificate issued by the state of

Connecticut).

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

of the sale or delivery of body armor, 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 General Statutes § 53-341b (c).

2 The transferee must possess “a permit or certificate issued under the provisions of [General

Statutes §§] 29-28 [permit to sell or carry pistol or revolver], 29-36f [eligibility certificate for

pistol or revolver], 29-37p [long gun eligibility certificate] or 29-38n [ammunition certificate].”

General Statutes § 53-341b (a) (2).