Conn. Crim. Jury Instr. 8.5-4

The defendant is charged [in count__] with falsely reporting an incident concerning serious

physical injury or death. The statute defining this offense reads in pertinent part as follows:

a person is guilty of falsely reporting an incident concerning serious physical injury

or death when such person commits the crime of falsely reporting an incident in the

second degree and such false report is of the alleged occurrence or impending

occurrence of the serious physical injury or death of another person.

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

beyond a reasonable doubt:

Element 1 - Committed falsely reporting an incident in the second degree

The first element is that the defendant committed the crime of falsely reporting an incident in the

second degree. <Insert the elements from Falsely Reporting an Incident in the Second Degree,

Instruction 8.5-5.>

Element 2 - Concerning serious physical injury or death

The second element is that the false report was of the alleged occurrence or impending

occurrence of the serious physical injury to or death of another person. “Impending” means

about to happen.

“Physical injury” means impairment of physical condition or pain. “Serious physical injury” is

something more serious than mere physical injury. It is more than a minor or superficial injury.

It is defined by statute as “physical injury that creates a substantial risk of death, or that causes

serious disfigurement, serious impairment of health or serious loss or impairment of the function

of any bodily organ.”

Conclusion

In summary, the state must prove beyond a reasonable doubt that <insert the concluding

summary from the instruction for falsely reporting an incident in the second degree>, and that

the false report concerned the (serious physical injury / death) of another person.

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

of falsely reporting an incident concerning serious physical injury or death, 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.