Conn. Crim. Jury Instr. 8.7-2

The defendant is charged [in count__] with computer crime in furtherance of terrorist purposes.

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

a person is guilty of computer crime in furtherance of terrorist purposes when such

person, with intent to intimidate or coerce the civilian population or a unit of

government, commits computer crime.

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

beyond a reasonable doubt:

Element 1 - Committed computer crime

The first element is that the defendant committed a computer crime.

<See 9.6 Computer Crimes and 10.5 Internet Crimes for the various computer crimes.>

Element 2 - Intent

The second element is that the defendant specifically intended to intimidate or coerce the civil

population or a unit of government. “Intimidate” has its ordinary meaning. “Coerce” means to

compel or induce another to do something, or not to do something, by instilling fear in that

person. “Civilian population” has its ordinary meaning. “Unit of government” means any unit

of any branch, subdivision or agency of the state, or any locality within it. <Insert specific

allegations.>

Conclusion

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

computer crime, and 2) (he/she) did so with the intent to intimidate or coerce the civil population

or a unit of government.

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

of computer crime for a terrorist purpose, 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 As defined in General Statutes § 53a-251, or a violation of any provision of General Statutes §

53-451.