Conn. Crim. Jury Instr. 8.3-6

The defendant is charged [in count__] with illegal (sale / possession) of a master car key. The

statute defining this offense imposes punishment on <insert as appropriate:>

• any person who makes and sells to anyone other than a new car dealer, a person actually

engaged in the trade of locksmith, a law enforcement agency, loan institution which

finances the purchase of motor vehicles any motor vehicle master car key.

• any person other than one engaged in the manufacture of such keys as a bona fide

business or other than one to whom the sale of such a key is authorized by this section

who has a motor vehicle master car key in (his/her) possession.

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 possessed a master car key

The first element is that the defendant (made and sold / possessed) a motor vehicle master car

key. A motor vehicle master car key is a key which can be used to open and operate multiple

motor vehicles. “Motor vehicle” has its ordinary meaning and includes an automobile.

Element 2 - Not authorized

<Insert as appropriate:>

• The second element is that the defendant sold the master car key to <insert name of

purchaser> and that (person / agency) was not a new car dealer, a person actually

engaged in the trade of locksmith, a law enforcement agency, or a loan institution which

finances the purchase of motor vehicles.

• The second element is that at the time of such possession the defendant was not engaged

in the manufacture of such keys as a bona fide business or was not a new car dealer

licensed under Connecticut law or was not an person actually engaged in the trade of

locksmith or was not a law enforcement agent or was not a loan institution that finances

the purchase of motor vehicles.

“Possession” means either having the (substance / object) on one’s person or otherwise

having control over the (substance / object), that is, knowing where it is and being able to

access it. Possession also requires that the defendant knew that (he/she) was in

possession of the master car key. That is, that (he/she) was aware that (he/she) was in

possession of it and was aware of its nature. The state must prove beyond a reasonable

doubt that the defendant knew that (he/she) was in possession of the master car key.

<See Knowledge, Instruction 2.3-3.> <See Possession, Instruction 2.11-1.>

Conclusion

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

sold / possessed) a motor vehicle master car key, and 2) the <insert as appropriate:>

• purchaser was not a new car dealer, a person actually engaged in the trade of locksmith, a

law enforcement agency, a loan institution which finances the purchase of motor

vehicles.

• the defendant was not engaged in the manufacture of such keys as a bona fide business or

was not a new car dealer licensed under Connecticut law or was not a person actually

engaged in the trade of locksmith or was not a law enforcement agent or was not a loan

institution that finances the purchase of motor vehicles.

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

of the (sale / possession) of a master car key, 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.