Conn. Crim. Jury Instr. 8.2-43

The defendant is charged [in count ___] with sale of (ammunition / an ammunition magazine).

The statute defining this offense reads in pertinent part as follows:

No person, firm, or corporation shall sell ammunition or an ammunition magazine to

any person under eighteen years of age.

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

beyond a reasonable doubt:

Element 1 – Sale of (ammunition / an ammunition magazine)

The first element is that the defendant sold (ammunition / an ammunition magazine).

The term “sell” shall be given its common meaning.

<Insert as applicable:>

• “Ammunition” means a loaded cartridge, consisting of a primed case, propellant or

projectile, designed for use in any firearm.

• An ammunition “magazine” means any firearm magazine, belt, drum, feed strip or

similar device that accepts ammunition.

A “firearm” means any sawed-off shotgun, machine gun, rifle, shotgun, pistol, revolver or other

weapon, whether loaded or unloaded from which a shot may be discharged.

The state alleges that the defendant sold (ammunition / an ammunition magazine) to <insert

name of person>.

Element 2 – To a person under 18 years old

The second element is that the defendant sold (ammunition / an ammunition magazine) to a

person under eighteen years of age. This means that the person to whom the defendant sold the

(ammunition / ammunition magazine) had not yet reached (his/her) eighteenth birthday at the

time of the alleged sale.

The state alleges that <insert name of person> was under eighteen years old at the time of the

alleged sale.

Conclusion

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

(ammunition / an ammunition magazine) to <insert name of person> and 2) <insert name of

person> was under eighteen years of age at the time of the alleged sale. If you unanimously find

that the state has proved beyond a reasonable doubt each of the elements of the crime of sale of

(ammunition / an ammunition magazine) to a minor, 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.

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1 General Statutes § 29-38m (a).

2 General Statutes § 29-38m (a).

3 General Statutes § 29-38m incorporates the definition of “firearm” in General Statutes § 53a-3

(19), which requires that the firearm be operable.

4 The statutory text is silent regarding whether the state also must prove that the defendant knew

that the buyer was under eighteen years old.