Conn. Crim. Jury Instr. 9.1-5

Note: Larceny from the person is defined as second degree larceny in § 53a-123 (3)

regardless of the nature or value of the property stolen.

The defendant is charged [in count__] with larceny in the second degree. The statute defining

this offense reads in pertinent part as follows:

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 defendant is charged with committing

larceny by taking the property from the person of another.

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 property

The first element is that the defendant wrongfully took property from the property owner.

<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 such property, (he/she) intended to

<insert as appropriate:>

• permanently deprive the owner of (his/her) property

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

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

Element 3 - From the person

The third element is that the defendant took the property from the person of another. This means

that the item taken was actually on the body or held by or was in some manner attached to the

person of <insert name of person>. <Describe allegations.>

Conclusion

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

(took / obtained / withheld) property from the property owner, 2) (he/she) did so with the intent

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

(himself/herself) or a third person), and 3) (he/she) took the property from <insert name of

person>’s person.

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

of the crime of larceny in the second degree, 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.