Conn. Crim. Jury Instr. 9.5-12

The defendant is charged [in count__] with criminal trover in the first degree. The statute

defining this offense reads in pertinent part as follows:

a person is guilty of criminal trover in the first degree when (he/she) forcibly enters or

forcibly removes the ignition of the motor vehicle of another and uses the motor

vehicle without the consent of such owner, and such use results in damage to or

diminishes the value of such motor vehicle or subjects such owner to economic loss,

fine or other penalty.

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

beyond a reasonable doubt:

Element 1 - Forcibly entered or removed the ignition of a motor vehicle

The first element is that the defendant forcibly (entered / removed the ignition of) a motor

vehicle of another. A motor vehicle has its ordinary meaning and includes <insert type of motor

vehicle alleged>.

Element 2 - Used motor vehicle without consent of owner

The second element is that the defendant used the motor vehicle without the consent of the

owner. “Owner” means not only the true or lawful owner, but any person who has a superior

right to that of the defendant. A person does an act “without consent of another person” when

(he/she) lacks such other person’s agreement or assent to engage in the act.

Element 3 - Damage to vehicle or other economic loss

The third element is that the defendant’s use of the motor vehicle without the owner’s consent

• resulted in damage to or diminished the value of the motor vehicle.

• subjected the owner of the vehicle to economic loss, fine or other penalty.

Conclusion

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

(entered / removed the ignition of) a motor vehicle of another, 2) (he/she) used the motor vehicle

without the consent of the owner, and 3) <insert specific allegations regarding damages, loss,

fine or penalty>.

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

of the crime of criminal trover in the first 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.