Conn. Crim. Jury Instr. 8.2-39

The defendant is charged [in count__] with the manufacture of bombs. The statute defining this

offense reads in pertinent part as follows:

any person, other than one engaged in the manufacture of firearms or explosives or

incendiary devices for lawful purposes, who fabricates in any manner, any type of an

explosive, incendiary or other device designed to be dropped, hurled or set in place to

be exploded by a timing device, shall be guilty.

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

beyond a reasonable doubt:

Element 1 - Fabricated incendiary device

The first element is that the defendant fabricated

1 an explosive, incendiary or other device

designed to be dropped, hurled, or set in place to be exploded by a timing device. The term

“explosive or incendiary device” means (A) dynamite and all other forms of high explosives, (B)

any explosive bomb, grenade, missile or similar device, and (C) any incendiary bomb or grenade,

fire bomb or similar device, including any device which (i) consists of or includes a breakable

container which contains a flammable liquid or compound and a wick composed of any material

which, when ignited, is capable of igniting such flammable liquid or compound, and (ii) can be

carried or thrown by an individual.

Element 2 - No lawful purpose

The second element is that the defendant was not engaged in the manufacture of the device for

lawful purposes.

Conclusion

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

<insert type of device alleged>, and 2) that (he/she) was not engaged in the lawful manufacture

of such devices.

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

of the manufacture of bombs, 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 The phrase “in any manner” modified “fabricate” to encompass a wide range of actions within

its definition. State v. Jamison, 152 Conn. 753, 759-60 (2014) (gluing pennies onto an existing

explosive device constitutes fabricating a bomb).

Firearms Trafficking

8.2-40 Firearms Trafficking -- § 53-202aa