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Criminal Jury Instructions

Criminal Jury Instructions Home

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

New, May 20, 2010

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 commits coercion and the other person is compelled or induced to (1) engage in conduct that constitutes prostitution, or (2) provide labor or services.

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

Element 1 - Intent to compel or induce
The defendant must have specifically intended to compel or induce the other person to engage in specific conduct. 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 - Compelled or induced
The second element is that the defendant compelled or induced another person to (engage in conduct that constitutes prostitution / provide labor or services). "Compel" means to force or constrain to do something. "Induce" means to move to action by persuasion or by influence. <Insert specific allegations.>

Element 3 - By means of fear
The third element is that the defendant did this by instilling in <insert name of complainant> a fear that, if the demand was not complied with, then the defendant or another person would <insert as appropriate:>

  • commit a criminal offense.
  • accuse a person of a criminal offense.
  • expose a secret tending to subject a person to hatred, contempt or ridicule, or to impair a person's credit or business repute.
  • take or withhold action as an official, or cause an official to take or withhold action.
<Insert specific allegations.>

Conclusion

In summary, the state must prove beyond a reasonable doubt that 1) the defendant specifically intended to compel or induce <insert name of complainant> to engage in certain conduct, 2) the defendant compelled or induced <insert name of complainant> to (engage in conduct that constitutes prostitution / provide labor or services), and 3) did so by instilling fear in <insert name of complainant> that <insert specific allegations>.

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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