Conn. Crim. Jury Instr. 8.3-9

The defendant is charged [in count__] with operating a motor vehicle without an ignition

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

No person shall operate a motor vehicle in violation of a restriction or limitation

placed on such person’s license or right to operate a motor vehicle in this state not to

operate any motor vehicle unless such motor vehicle is equipped with an ignition

interlock device.

For you to find the defendant guilty of this charge, the state must prove beyond a reasonable

doubt the following elements:

Element 1 - Operated a motor vehicle

The first element is that the defendant (operated / caused to be operated) a motor vehicle. A

“motor vehicle” means all vehicles used on a public highway and include automobiles. A person

“operates” a motor vehicle within the meaning of the statute when, while in the vehicle, such

person intentionally does any act or makes use of any mechanical or electrical agency that alone,

or in sequence, will set in motion the motive power of the vehicle. A person acts “intentionally”

with respect to conduct when (his/her) conscious objective is to engage in such conduct. <See

Intent: General, Instruction 2.3-1.>

Element 2 - In violation of an order

The second element is that such operation occurred during a period when the person’s right to

operate a motor vehicle was limited or restricted by an order not to operate any motor vehicle

unless such motor vehicle is equipped with an ignition interlock device.

Conclusion

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

motor vehicle, and 2) at the time the defendant was under an order not to operate a motor vehicle

unless it is equipped with an ignition interlock device.

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

of operating a motor vehicle without an ignition interlock device, 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.