STATE v. DARRYL CRENSHAW, SC 18745

Judicial District of Hartford

 

†††† †Criminal; Whether Trial Court Properly Consolidated Defendantís two Criminal Cases; Whether the Evidence was Sufficient to Support Defendantís Kidnapping Convictions.† The state brought two criminal cases against the defendant, alleging, in the first case, that he kidnapped and assaulted his girlfriend, Ashley Peoples, in Hartford, and, in the second case, that he kidnapped and murdered Peoples in Enfield.† At trial, the state filed a motion to consolidate the cases.† The defendant objected to the motion, arguing that trying the cases together would be prejudicial to him because the graphic evidence regarding the murder charge in the second case would likely cause the jury to return a verdict of guilty on the charges in the first case.† He explained that the evidence related to the murder charge would be particularly brutal and shocking in that it would include detailed testimony and photographic evidence revealing that Peoples suffered multiple head injuries, internal injuries around the stomach area, bruising on both arms and scratches on her neck.† He also contended that the jury would likely assume that because he was charged with numerous criminal offenses, he must have done something wrong and that it would be tempted to cumulate the evidence against him even though the evidence in each case was not cross admissible.† He further claimed that the jury would likely use the evidence regarding the kidnapping charge in the Enfield case, which, he maintained, was stronger than the evidence related to the kidnapping charge in the Hartford case, to return guilty verdicts on both kidnapping charges.† The trial court granted the motion to consolidate, finding that certain facts from the Hartford case regarding the defendantís intent and motive would be admissible in the Enfield case.† It also opined that the two cases involved distinct offenses and that it could give jury instructions that would ensure that the cases would be treated separately.† It further determined that although the forensic evidence regarding the murder charge would be upsetting, it was not so extraordinarily brutal or shocking as to preclude the consolidation of the cases for trial.† After the state presented its case, the defendant moved for a judgment of acquittal, arguing that there was insufficient evidence to support the kidnapping charges.† He maintained that there was no evidence that the defendant ever abducted Peoples and that, to the contrary, the stateís witnesses indicated that Peoples had voluntarily accompanied the defendant.† The court denied the defendantís motion, and he was convicted of murder, two counts of kidnapping in the second degree and one count of assault in the third degree.† In this appeal, the Supreme Court will determine whether the trial court properly granted the stateís motion to consolidate the two cases and denied the defendantís motion for a judgment of acquittal as to the kidnapping charges.