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Criminal Jury Instructions

Criminal Jury Instructions Home

2.6-9  Stipulations

Revised to December 1, 2007

In this case evidence in the form of a stipulation between the parties was introduced to show <insert facts stipulated to>.  A stipulation is an agreement between the parties concerning some fact, which you as the jury are bound to accept as fact during your deliberations.  A stipulation does not, however, establish proof of the element of the crime beyond a reasonable doubt.  This stipulation is court exhibit #__.  This item is an agreement by both sides.  This stipulation is only numbered as an exhibit as a housekeeping matter.  No other exhibit is a stipulation, a fact agreed to by both sides.

These stipulations are to be used only for the specific purposes they were entered into for, and not to be used for any other purpose.  The stipulations do not include credibility or the weight you may give to the exhibits.  You will have these stipulations with you during your deliberations.


When a prior conviction is an element of the offense, e.g., criminal possession of a pistol or revolver, the defendant will often stipulate to it.  An instruction limiting its use is necessary to prevent prejudice as to any other crimes alleged.  See State v. Hair, 68 Conn. App. 695, 698-99 n.5, cert. denied, 260 Conn. 925 (2002); State v. Abraham, 64 Conn. App. 384, 397-99, cert. denied, 258 Conn. 917 (2001); State v. Taylor, 52 Conn. App. 790 (1999); State v. Davis, 51 Conn. App. 171, 184 (1998).


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