Conn. Crim. Jury Instr. 9.1-4

Note: General Statutes § 53a-119c, effective October 1, 2022, proscribes larceny of a motor

vehicle and provides for increasing penalties for second and subsequent offenses. Prior to

the enactment of § 53a-119c, this crime was encompassed by the general larceny statutes,

with the degree of larceny determined by the value of the motor vehicle. See General

Statutes (Rev. to 2021) §§ 53a-122 (first degree); 53a-123 (second degree); and 53a-124

(third degree). The dollar amounts for the degrees of larceny were increased as of October

1, 2009. See the table in Introduction to Larceny for the values in effect prior to that date.

The defendant is charged [in count__] with larceny of a motor vehicle. The statute defining this

offense reads in pertinent part as follows:

a person commits larceny of a motor vehicle when such person commits larceny and

the property consists of a motor vehicle. A person commits larceny when, with intent

to <insert as appropriate:>

• deprive another of property,

• appropriate property to (himself/herself) or a third person,

(he/she) wrongfully (takes / obtains / withholds) such property from an owner.

Larceny simply means theft or stealing. In this case, the property allegedly stolen is a motor

vehicle.

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

beyond a reasonable doubt:

Element 1 - Theft of motor vehicle

The first element is that the defendant wrongfully (took / obtained / withheld) a motor vehicle

from the vehicle’s owner. “Motor vehicle” has its ordinary meaning and includes any

(construction equipment / agricultural tractor / farm implement / major component part of a

motor vehicle).

1 <Identify the type of vehicle allegedly stolen.>

<See Larceny, Instruction 9.1-1, for a full explanation of this element.>

Element 2 - Larcenous intent

The second element is that at the time the defendant (took / obtained / withheld) the motor

vehicle, (he/she) intended to <insert as appropriate:>

• permanently deprive the owner of (his/her) vehicle.

• permanently appropriate the vehicle to (himself/herself) or a third person.

<See Larceny, Instruction 9.1-1, for a full explanation of this element.>

A person acts “intentionally” with respect to a result when (his/her) conscious objective is to

cause such result. <See Intent: Specific, Instruction 2.3-1.>

[<Insert if applicable:> The statute defining the offense of theft of a motor vehicle provides that

certain evidence, if believed, may be sufficient to establish intent.

2 If you find that the defendant

was in control of or possessed a motor vehicle that had been subject to (forcible entry / forcible

removal of the ignition / alteration, mutilation or removal of the vehicle identification number),

you may then find, but are not required to, that (he/she) knew or should have known that it was

stolen, and that (he/she) had the intent to (deprive the owner of the vehicle / appropriate the

vehicle to (himself/herself) or a third person. The state must still prove beyond a reasonable

doubt that the defendant was the person who stole the motor vehicle involved.]

Conclusion

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

(took / obtained / withheld) a motor vehicle from the owner and 2) (he/she) did so with the intent

to (permanently deprive the owner of (his/her) vehicle / permanently appropriate the vehicle to

(himself/herself) or a third person).

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

of the crime of larceny of a motor vehicle, 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 See General Statutes § 53a-119c (b).

2 Id.