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Section 16-20.Requests To Charge and Exceptions; Necessity for

Current through August 12, 2025 (2026 Practice Book edition) · Last verified July 9, 2026

In one sentenceTo challenge a jury instruction on appeal, a party must have covered the issue in a written request to charge or must have objected right after the charge was read, stating the specific error and ground while the jury is out of the room.

Full Text of Section 16-20

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An appellate court shall not be bound to consider error as to the giving of, or the failure to give, an instruction unless the matter is covered by a written request to charge or exception has been taken by the party appealing immediately after the charge is delivered. Counsel taking the exception shall state distinctly the matter objected to and the ground of objection. The exception shall be taken out of the hearing of the jury.

Amendment History

(P.B. 1978-1997, Sec. 315.)

Plain-English Summary

An appellate court will not consider a claim that the trial judge gave a wrong instruction, or wrongly left one out, unless the party raising the claim first gave the trial court a chance to fix it. That happens one of two ways: the party filed a written request to charge covering the matter, or the party’s counsel took an exception immediately after the judicial authority finished delivering the charge to the jury.

An exception is not a bare objection. Counsel taking it must state distinctly what was objected to and the ground for the objection, so the judicial authority understands exactly what is being challenged and why. The exception itself must be taken outside the jury’s hearing, keeping the jury from being influenced by the legal dispute over the instructions it just received.

Frequently Asked Questions

How do I preserve an objection to a jury instruction for appeal in Connecticut?

Either file a written request to charge covering the disputed matter, or have counsel take an exception immediately after the charge is delivered, stating distinctly the matter objected to and the ground for objection.

What happens if I never object to a jury instruction at trial?

An appellate court is not bound to consider a claim of error about that instruction unless a written request to charge or a timely exception covered it.

Can the jury hear my exception to the judge’s charge?

No. Section 16-20 requires that the exception be taken out of the jury’s hearing.

What must an exception to a jury charge include?

Counsel must state distinctly the matter objected to and the ground of the objection, not just a general objection to the charge.

Source & verification. The section text is reproduced verbatim from the official Connecticut Practice Book (Conn. Practice Book § 16-20). Prescribed by the Judges of the Superior Court of Connecticut (Conn. Gen. Stat. Section 51-14). The plain-English summary is original and written by us. Last verified July 9, 2026. · Official source
Also known as: preserving jury instruction error CTrequests to charge appealexception to jury charge Connecticuttaking exception to instructionshow to object to jury instructions