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Criminal Jury Instructions

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6.12-2 Trafficking in Persons -- § 53a-192a

Revised November 6, 2014

Note: This instruction is for crimes committed on or after October 1, 2013.  Public Act No.13-166, § 2, substantially revised the definition of the offense.  For crimes committed before October 1, 2013, see Instruction 6.12-2A in the Archive.

The defendant is charged [in count __] with trafficking in persons. The statute defining this offense reads in pertinent part: 

a person is guilty of trafficking in persons when such person compels or induces another person to (engage in conduct involving more than one occurrence of sexual contact with one or more third persons / provide labor or services that such person has a legal right to refrain from providing), by means of (the use of force against such other person or a third person, or by the threat of use of force against such other person or a third person / fraud / coercion).

For you to find the defendant guilty of this charge, the state must prove the following elements beyond a reasonable doubt:

Element 1 - Compelled or induced
The first element is that the defendant compelled or induced another person to

  •  engage in conduct involving more than one occurrence of sexual contact with one or  more third persons.

  •  provide labor or services that the person has a legal right to refrain from providing.

"Compel" means to force or constrain to do something. "Induce" means to move to action by persuasion or by influence.

“Sexual contact" means any contact with the intimate parts of another person.

The defendant must have specifically intended to compel or induce the other person <insert specific allegations>.  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.> 

Element 2 - By means of
The second element is that the defendant did this by

  • (the use of force / the threat of use of force) against the person or a third person.
  • fraud. The meaning of "fraud," both in is legal usage and its common usage, is the same: a deliberately planned purpose and intent to cheat or deceive or unlawfully deprive someone of some advantage, benefit or property.
  • coercion. <See Coercion, Instruction 6.12-1.>
<Insert specific allegations.>em>

Conclusion

In summary, the state must prove beyond a reasonable doubt that 1) the defendant specifically intended to compel or induce to (engage in conduct that constitutes prostitution / provide labor or services), and 2) did so by ((the use of force / the threat of the use of force) against <insert name of complainant or third person) / fraud / coercion).

If you unanimously find that the state has proved beyond a reasonable doubt each of the elements of the crime of trafficking in persons, 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.


 

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