AC47513 - State v. Marcus ("The defendant, Alphonso Marcus, appeals from the judgment of conviction, rendered after a trial to the court, of assault of a correctional officer in violation of General Statutes § 53a-167c. On appeal, the defendant claims that there was insufficient evidence to support his conviction because there was no evidence that he caused physical injury. Specifically, he challenges the court’s finding that the correctional officer suffered any physical injury. We affirm the judgment of the trial court.")

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• Criminal Law & Procedure,
• Recent Opinions

AC47193 - State v. Jordan ("The defendant, Zyron Amir Jordan, appeals from the judgments of the trial court finding him in violation of probation under General Statutes § 53a-32. On appeal, the defendant principally claims that there was insufficient evidence that he violated his probation. We disagree with this claim. However, because we conclude that one of the two grounds on which the court found the defendant in violation of his probation was not supported by sufficient evidence, and because we cannot be confident that this error did not impact the sentences it imposed, we set aside the defendant's sentences and remand the matter for resentencing.")

• Posted in:
• Criminal Law & Procedure,
• Recent Opinions

AC47223 - State v. Britto ("The defendant, David Britto, appeals from the judgment of conviction, rendered after a jury trial, of sexual assault in the first degree in violation of General Statutes § 53a-70 (a) (1), unlawful restraint in the first degree in violation of General Statutes § 53a-95 (a), and assault in the third degree in violation of General Statutes § 53a-61 (a) (1). On appeal, the defendant claims that the trial court (1) inadequately canvassed him to determine whether his waiver of his right to counsel was knowing, voluntary and intelligent, and (2) violated his due process rights, including his right to present a defense, when it denied his request for a continuance to obtain a DNA expert. We agree with the defendant's first claim and, accordingly, reverse the judgment of the trial court.")

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• Criminal Law & Procedure,
• Recent Opinions

AC47637 - State v. Haughey ("The defendant, Norman Haughey, appeals from the judgment of the trial court dismissing his motion for modification of his sentence pursuant to General Statutes § 53a-39 (a). On appeal, the defendant claims that the court erred in its determination that his definite sentence of life imprisonment without the possibility of release imposed a mandatory minimum sentence that was precluded from modification under § 53a-39 (d). Although we agree with the trial court that § 53a-39 (d) precludes modification of the defendant’s sentence, we conclude that the trial court improperly determined that it lacked jurisdiction. Therefore, the form of the judgment is improper, as the court should have denied, rather than dismissed, the motion. Accordingly, we reverse the judgment dismissing the defendant’s motion for modification of his sentence and remand the case with direction to deny the motion.")

• Posted in:
• Criminal Law & Procedure,
• Recent Opinions

SC20815 - State v. Sharpe (“This appeal requires us to determine, among other things, whether the police may, without a warrant, collect DNA found on lawfully obtained items and analyze the DNA for identification purposes. The defendant, Michael Sharpe, appeals from the judgment of conviction, rendered after a jury trial, of eight counts of kidnapping in the first degree. He claims that the extraction and testing of his DNA from a belt the police lawfully retrieved from his trash constituted an unreasonable search and seizure that violated his right to privacy under the fourth amendment to the United States constitution and article first, § 7, of the Connecticut constitution. He further claims that the trial court’s use of a flowchart as a guide to its lengthy instructions misled the jury because it omitted the factors this court articulated in State v. Salamon, 287 Conn. 509, 548, 949 A.2d 1092 (2008). We disagree and affirm the trial court’s judgment of conviction.”)

• Concurrence & Dissent

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• Criminal Law & Procedure,
• Recent Opinions

AC47294 - State v. Angel A. ("The defendant, Angel A., appeals from the judgment of conviction, rendered after a jury trial, of attempt to commit murder in violation of General Statutes §§ 53a-49 (a) (2) and 53a-54a, assault in the first degree in violation of General Statutes § 53a-59 (a) (1), and criminal violation of a protective order in violation of General Statutes § 53a-223 (c) (2). The defendant claims that the trial court improperly (1) violated his right to jury unanimity by discharging the jury before disclosing to the parties a postverdict comment made to the court by a member of the jury, C.A., following the acceptance of the verdict that she ‘‘[felt] a little guilty about the attempted murder charge,’’ and (2) violated his right to a fair trial by denying his request to question C.A. at a posttrial hearing about why she made that postverdict comment. We disagree and, accordingly, affirm the judgment of the court.")

• AC47294 Concurrence - State v. Angel A.
• AC47294 Dissent - State v. Angel A.

AC47503 - State v. Benson ("The defendant, Richard Benson, appeals from the judgment of conviction, rendered following his entry of guilty pleas pursuant to the Alford doctrine, of possession of narcotics with intent to sell in violation of General Statutes § 21a-277 (a) (1) (A), criminal possession of a pistol or revolver in violation of General Statutes § 53a-217c, and failure to appear in the first degree in violation of General Statutes § 53a-172. On appeal, the defendant claims, inter alia, that the court violated his right to self-representation under the sixth amendment to the United States constitution by failing to canvass him after he clearly and unequivocally asserted that he wanted to represent himself. We disagree and, accordingly, affirm the judgment of the trial court.")

AC46652 - State v. Ragalis ("The defendant, Ryan E. Ragalis, appeals from the judgment of conviction, rendered following a jury trial, of assault in the second degree with a motor vehicle in violation of General Statutes § 53a-60d1 and assault in the second degree in violation of General Statutes § 53a-60 (a) (3). On appeal, the defendant claims that (1) the evidence was insufficient to convict him of assault in the second degree with a motor vehicle and assault in the second degree, (2) his conviction of assault in the second degree with a motor vehicle and assault in the second degree violates the double jeopardy clause of the United States constitution, and (3) the trial court’s supplemental instructions to the jury in response to a note misled the jury. We affirm the judgment of the trial court.")

• Posted in:
• Constitutional Law,
• Criminal Law & Procedure,
• Recent Opinions

SC20865 - State v. Cooper ("After a jury trial, the defendant, Jahmari Cooper, was convicted of murder in violation of General Statutes § 53a-54a (a) for fatally shooting the victim, Jeri Kollock, Jr., when the defendant was seventeen years old. In this direct appeal pursuant to General Statutes § 51-199 (b) (3), the defendant claims that (1) the circumstances of his custodial police interrogation do not establish a knowing and voluntary waiver of his Miranda rights under the federal constitution, (2) even if this court concludes that the federal constitutional requirements were satisfied, he is entitled to greater protection under our state constitution, (3) prosecutorial impropriety during closing and rebuttal arguments deprived him of his constitutional right to a fair trial, and (4) the trial court erred in giving the jury a consciousness of guilt instruction. We affirm the judgment of the trial court.")

AC46997 - State v. Owens ("The self-represented defendant, Marvin Owens, appeals from the judgments of the trial court finding him in violation of the conditions of his probations and revoking his probations pursuant to General Statutes § 53a-32. The defendant claims that (1) the court improperly denied his motion to dismiss, which alleged violations of his right to a speedy trial and of the 120 day guideline contained in § 53a-32, (2) the court violated his constitutional right to self-representation, (3) the court found that he violated the conditions of his probations on the basis of insufficient evidence, and (4) the state violated his due process rights by failing to correct false or misleading testimony. We affirm the judgments of the court.")

• Posted in:
• Constitutional Law,
• Criminal Law & Procedure,
• Recent Opinions

SC20990 - State v. Henderson ("Nearly thirty years ago, then Justice Robert J. Callahan anticipated the need for a particularized evidentiary showing of extreme emotional disturbance in intimate partner homicide cases in order not to establish 'a per se rule that anyone who kills a former girlfriend or boyfriend is entitled to a jury instruction on extreme emotional disturbance.' State v. Person, 236 Conn. 342, 361–62 and n.1, 673 A.2d 463 (1996) (Callahan, J., dissenting). Justice Callahan's observation is instructive as we consider the appeal of the defendant, Carlton Henderson, who was convicted, after a jury trial, of the murder of his long-term girlfriend (victim) in violation of General Statutes § 53a-54a and risk of injury to a child in violation of General Statutes § 53-21 (a) (1). On appeal, the defendant claims that the trial court's denial of the defendant's request to instruct the jury on the affirmative defense of extreme emotional disturbance under § 53a-54a (a) entitles him to a new trial. We disagree and affirm the judgment of conviction.")

• SC20990 Dissent - State v. Henderson

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• Criminal Law & Procedure,
• Recent Opinions

SC20784 - State v. Dixon ("The most significant issue raised in this appeal is whether the trial court properly allowed the state's gang expert to testify as to 'neighborhoods,' 'neighborhood divisions,' and the 'dynamics' between neighborhoods in the city of Stamford, despite the fact that the prosecutor conceded that the defendant, Sirus Dixon, was not in a gang. The defendant also raises various other claims, including that the court failed to provide certain proposed jury instructions, the jury returned an inconsistent verdict, and there was insufficient evidence to sustain his conviction. Although we agree with the defendant that the admission of the testimony from the state's gang expert witness was improper, we conclude that this error was harmless. We also reject the defendant's other claims. Accordingly, we affirm the judgment of conviction.")

• SC20784 Concurrence - State v. Dixon

• Posted in:
• Criminal Law & Procedure,
• Recent Opinions

SC20728 - State v. Correa ("This appeal requires us to examine, among other things, the level of particularity required for a warrant to search and seize a cell phone's data. The defendant, Sergio J. Correa, appeals from the judgment of conviction, rendered after a jury trial, of one count of murder with special circumstances, two counts of arson in the second degree, two counts of robbery in the first degree, and one count of home invasion. He claims that his rights under the fourth amendment to the United States constitution and article first, § 7, of the Connecticut constitution were violated when the police (1) seized his cell phone without a warrant, and (2) obtained a warrant to search and seize "all data" on the cell phone. Assuming the seizure of the defendant's cell phone was constitutional, we conclude that the warrant violated the fourth amendment because it was insufficiently particular. Accordingly, the evidence obtained from the defendant's cell phone should have been suppressed. However, we affirm the trial court's judgment of conviction because we conclude that the error was harmless beyond a reasonable doubt.")

AC47370 - State v. Wright ("The defendant, Randy A. Wright, appeals from the judgment of conviction, rendered after a jury trial, of one count of sexual assault in the first degree in violation of General Statutes § 53a-70 (a) (2), one count of sexual assault in the second degree in violation of General Statutes § 53a-71 (a) (1), and two counts of risk of injury to a child in violation of General Statutes § 53-21 (a) (2). On appeal, the defendant claims that (1) the evidence was insufficient to support his conviction of sexual assault in the second degree and one of his convictions of risk of injury to a child, (2) the trial court improperly denied his midtrial request for a lengthy continuance in order to seek new counsel or prepare to represent himself, (3) the trial court erred in failing to advise him of the consequences of failing to appear and in trying and sentencing him in absentia after he absconded during his trial, (4) the trial court improperly denied the request by the defendant's counsel, Vincent Fazzone, for a mistrial when the defendant failed to appear on the second day of evidence, (5) the trial court improperly failed to sua sponte declare a mistrial and remove Fazzone as defense counsel, and (6) the trial court improperly prevented Fazzone from cross-examining the victim about a prior accusation of sexual misconduct that she allegedly had made. We dismiss the appeal as to the defendant's sixth claim and otherwise affirm the judgment of the court.")

AC46683 - State v. Trice ("The defendant, Shife Trice, appeals from the judgment of conviction, rendered after a trial to the court, of robbery in the second degree in violation of General Statutes § 53a-135 (a) (1) (B). On appeal, the defendant claims that (1) the court improperly failed to conduct, sua sponte, an independent inquiry into his competence, (2) there was insufficient evidence presented at trial to support his conviction, (3) the court violated his constitutional right to self-representation, and (4) the court abused its discretion by admitting a certain hearsay statement into evidence. We disagree and, accordingly, affirm the judgment of the trial court.")

• Posted in:
• Constitutional Law,
• Criminal Law & Procedure,
• Recent Opinions

SC20802 - State v. McFarland ("In August, 1987, the decomposed bodies of the victims, Fred Harris and his son, Gregory Harris, were found murdered in an apartment they shared in Hamden. The crime went unsolved until 2019, when scientific advancements in DNA testing led to the arrest of the defendant, Willie McFarland. The defendant now appeals from his conviction of both murders, following a jury trial in 2022. The primary issue on appeal is whether the thirty-two year delay between the 1987 murders and his 2019 arrest violated the defendant's right to due process under the federal and state constitutions. The defendant also claims that the trial court abused its discretion by (1) declining to order a new competency evaluation after previously finding him competent to stand trial, and (2) finding that a deceased witness' statements included in police reports were not admissible under the residual exception to the hearsay rule because they did not manifest the required guarantees of trustworthiness and reliability. We affirm the judgment of conviction.")

• SC20802 Concurrence - State v. McFarland
• SC20802 Second Concurrence - State v. McFarland
• SC20802 Third Concurrence - State v. McFarland

AC47138 - State v. William A. ("The defendant, William A., appeals from the judgment of conviction, rendered after a jury trial, of sexual assault in the fourth degree in violation of General Statutes § 53a-73a (a) (1) (A) and risk of injury to a child in violation of General Statutes § 53-21 (a) (2). On appeal, the defendant claims that (1) pursuant to Doyle v. Ohio, 426 U.S. 610, 619, 96 S. Ct. 2240, 49 L. Ed. 2d 91 (1976), the state violated his fifth amendment right to remain silent when the prosecutor impermissibly asked a question and elicited testimony during the state's case-in-chief and commented during closing argument about the defendant's post-Miranda silence, (2) the prosecutor's improper question about the defendant's post-Miranda silence implicated the defendant's constitutional right to have the state prove his guilt beyond a reasonable doubt and thereby implied that the defendant had to prove his innocence, in violation of In re Winship, 397 U.S. 358, 364, 90 S. Ct. 1068, 25 L. Ed. 2d 368 (1970), (3) the prosecutor engaged in improprieties during the trial and closing argument that deprived the defendant of his due process right to a fair trial, and (4) the trial court committed plain error by instructing the jury on consciousness of guilt when there was no evidence to support such an instruction and the instruction did not comply with the model Connecticut Criminal Jury Instructions. We agree that the prosecutor impermissibly asked a question and elicited testimony about the defendant's post-Miranda silence in violation of Doyle and conclude that the state has failed to meet its burden of demonstrating that the constitutional violation was harmless beyond a reasonable doubt. Accordingly, we reverse the judgment of conviction and remand the case for a new trial.")

• Posted in:
• Constitutional Law,
• Criminal Law & Procedure,
• Recent Opinions

SC20781 - State v. Jacques ("The defendant, Jean Jacques, appeals from the judgment of conviction, rendered after a jury trial, of one count of murder in violation of General Statutes § 53a-54a (a). On appeal, the defendant claims that the trial court (1) violated his state constitutional right to a probable cause hearing by denying his request for a second probable cause hearing after this court reversed his previous conviction and remanded the case for a new trial in State v. Jacques, 332 Conn. 271, 294, 210 A.3d 533 (2019), (2) violated his confrontation clause rights under the sixth amendment to the United States constitution, as well as abused its discretion, by admitting Tywan Jenkins' written statement to the police as a prior inconsistent statement under State v. Whelan, 200 Conn. 743, 513 A.2d 86, cert. denied, 479 U.S. 994, 107 S. Ct. 597, 93 L. Ed. 2d 598 (1986), and (3) abused its discretion in finding that the state had made a prima facie showing that the testimony of Danny Vazquez, a jailhouse informant, was reliable and admissible under General Statutes § 54-86p. We affirm the judgment of conviction.")

• Posted in:
• Constitutional Law,
• Criminal Law & Procedure,
• Recent Opinions

SC20829 - State v. Foster ("The principal issue in this certified appeal is whether, for purposes of an equal protection challenge, an insanity acquittee who is subject to a petition under General Statutes § 17a-593 for continued commitment to the custody of the Psychiatric Security Review Board (board) following the expiration of the maximum period of commitment is similarly situated to a mentally ill prison inmate who is the subject of a petition for civil commitment pursuant to General Statutes §§ 17a-498 (c) and 17a-515 (civilly committed inmate). We conclude that an insanity acquittee who is subject to a petition for continued commitment, regardless of his clinical progress, is not similarly situated to a civilly committed inmate for purposes of the equal protection guarantees under the fourteenth amendment to the United States constitution.

The acquittee, Franklin Foster, appeals, upon our grant of his petition for certification, from the judgment of the Appellate Court, which affirmed the judgment of the trial court granting the state's petition to extend his commitment to the custody of the board. See State v. Foster, 217 Conn. App. 476, 478, 506, 289 A.3d 191 (2023). On appeal, the acquittee claims, among other things, that the Appellate Court incorrectly concluded that (1) as an insanity acquittee, he was not similarly situated to a civilly committed inmate for purposes of a challenge to § 17a-593 under the equal protection clause of the fourteenth amendment to the United States constitution, and (2) the trial court's finding, pursuant to § 17a-593 (c), that he was mentally ill and dangerous was supported by clear and convincing evidence. We disagree and affirm the judgment of the Appellate Court.")

• SC20829 Concurrence - State v. Foster

SC21023 - State v. Guild ("This appeal requires us to consider whether the release of an insanity acquittee from the custody of the Psychiatric Security Review Board (board) moots his pending appeal challenging the trial court's order extending his commitment to the board that was issued on July 11, 2023 (2023 commitment order). In this appeal, the acquittee, Stephen Guild, has raised several factual and constitutional challenges to his continued commitment under General Statutes § 17a-593 (c). While this appeal was pending, on December 2, 2024, the state filed a new petition that would have extended the acquittee's commitment to the custody of the board beyond the acquittee's discharge date of March 20, 2025 (2024 petition). After conducting a hearing on the 2024 petition pursuant to § 17a-593 (d), the board filed a report dated January 22, 2025, in which it found that the acquittee was no longer a danger to himself or others as to require supervision by the board and recommended that the trial court deny the state's petition for further commitment. The state did not challenge the board's finding, and it withdrew the 2024 petition, which resulted in the acquittee's discharge from the custody of the board on March 20, 2025.

These events, which occurred during the pendency of this appeal, have rendered this appeal moot. Put simply, given that the acquittee has been released from the custody of the board on March 20, 2025, we cannot grant him any practical relief from the 2023 commitment order. Further, the acquittee has not established that there are any legally cognizable collateral consequences resulting from the 2023 commitment order, or that this is a matter that is capable of repetition, yet evading review. The acquittee was, however, precluded from fully litigating the correctness of the 2023 commitment order through no fault of his own, insofar as it was rendered moot when the state withdrew the 2024 petition. Accordingly, we dismiss the appeal but vacate the 2023 commitment order.")

• Posted in:
• Contract Law,
• Criminal Law & Procedure,
• Recent Opinions

AC46889 - State v. Nichols ("The defendant, Robert Lee Nichols, appeals from the judgment of conviction, rendered following a jury trial, of one count of assault in the first degree in violation of General Statutes § 53a-59 (a) (3) and two counts of risk of injury to a child in violation of General Statutes § 53-21 (a) (1). On appeal, the defendant claims that the trial court improperly (1) denied his motion for a judgment of acquittal because there was insufficient evidence for the jury to find him guilty on all counts, and (2) denied his motion for a new trial because the jury's verdict was against the manifest weight of the evidence. We disagree with the defendant's first claim. However, we are persuaded that the court applied an incorrect legal standard in adjudicating the defendant's motion for a new trial. Accordingly, we reverse the court's denial of the motion for a new trial and remand the case to the trial court, K. Doyle, J., for a new determination on that motion. The judgment is affirmed with respect to the defendant's claim that the evidence was insufficient to support his conviction.")

• Posted in:
• Criminal Law & Procedure,
• Recent Opinions

SC21006 - State v. Evans ("The defendant, Richard Evans, appeals from the trial court's judgment of conviction, rendered after a jury trial, of murder in violation of General Statutes § 53a-54a (a) and carrying a pistol without a permit in violation of General Statutes (Rev. to 2017) § 29-35 (a). The defendant claims that the trial court erred (1) in admitting a lay witness' testimony identifying him in a still photograph taken from a surveillance video, and (2) in denying, in part, his motion to suppress cell site location information (CSLI) that the police had acquired after obtaining a search warrant for those records. We affirm the judgment of the trial court.")

• SC21006 Concurrence - State v. Evans

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• Criminal Law & Procedure,
• Recent Opinions

SC20799 - State v. Myers ("A jury found that the defendant, Cornel Myers, murdered his former girlfriend (victim) after she attempted to end their romantic relationship. On appeal from the judgment of conviction of murder in violation of General Statutes § 53a-54a (a), the defendant claims that the trial court improperly (1) excluded certain third-party culpability evidence pertaining to the victim's neighbor, and (2) denied his motion for a mistrial when the prosecutor's questioning of a witness improperly shifted the burden of proof to the defendant. We disagree and affirm the judgment of conviction.")

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• Criminal Law & Procedure,
• Recent Opinions

AC46967 - State v. Henry B.-A. ("The defendant, Henry B.-A., appeals from the judgment of conviction, rendered following a jury trial, of sexual assault in the second degree in violation of General Statutes § 53a-71 (a) (1), risk of injury to a child in violation of General Statutes § 53-21 (a) (1), and two counts of risk of injury to a child in violation of § 53-21 (a) (2). On appeal, the defendant claims that he was deprived of his due process right to a fair trial as a result of prosecutorial improprieties that allegedly occurred during the prosecutor's closing and rebuttal arguments. We disagree and affirm the judgment of the court.")

AC46643 - State v. Calderon-Perez ("The defendant, Jayson Calderon-Perez, appeals from the judgment of conviction, rendered after a jury trial, of assault in the second degree in violation of General Statutes § 53a-60 (a) (6) and breach of the peace in the second degree in violation of General Statutes § 53a-181 (a) (1). On appeal, the defendant claims that the trial court deprived him of his right to present a defense under the sixth and fourteenth amendments to the federal constitution by (1) excluding, as irrelevant, evidence of his physical appearance six months after the crime, (2) prohibiting a defense witness from testifying due to late disclosure, (3) preventing the defense from presenting testimony from an expert in video graphics, and (4) limiting the defendant's cross-examination of a state's witness. In addition, the defendant claims that the prosecutor engaged in impropriety during the state's rebuttal closing argument, thereby depriving the defendant of his due process right to a fair trial under the fifth and fourteenth amendments to the federal constitution. We conclude that the trial court's exclusion of evidence of the defendant's appearance six months after the crime violated the defendant's constitutional right to present a defense. Accordingly, we reverse the judgment and remand the case for a new trial.")

AC47038 - State v. Colon ("The defendant, Israel Colon, appeals from the judgment of conviction rendered by the trial court following his conditional plea of nolo contendere to illegal possession of a weapon in a motor vehicle in violation of General Statutes § 29-38 (a) and possession of a narcotic substance with intent to sell in violation of General Statutes § 21a-277 (a) (1) (A). The defendant entered that plea after the court denied his motion to suppress evidence seized during a motor vehicle stop. The sole issue on appeal is whether the court properly denied the motion to suppress. We affirm the judgment of the trial court.")

• Posted in:
• Constitutional Law,
• Criminal Law & Procedure,
• Recent Opinions

SC20837 - State v. Parris ("A jury found the defendant, Robert Parris, guilty of, among other offenses, murder in violation of General Statutes § 53a-54a (a), for shooting and killing the victim, Michael Rosario. The defendant appeals from the judgment of the trial court, claiming that he is entitled to a new trial because (1) multiple instances of prosecutorial impropriety during the state's closing and rebuttal arguments deprived him of his right to a fair trial, and (2) the trial court abused its discretion in admitting portions of his statement to the police that included homophobic slurs. We agree with the defendant that there were multiple instances of prosecutorial impropriety that deprived him of a fair trial but disagree with him that the trial court abused its discretion in admitting his entire statement to the police. Because the defendant's due process right to a fair trial was violated, we reverse the judgment of the trial court as to the defendant's murder conviction and remand the case for a new trial on that charge.")

• SC20837 Concurrence & Dissent - State v. Parris

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• Criminal Law & Procedure,
• Recent Opinions

SC20785 - State v. McLaurin ("A jury found the defendant, Gregory E. McLaurin, guilty of numerous offenses related to a 2018 robbery of a Smashburger restaurant in Milford. On appeal to the Appellate Court, the defendant claimed that the trial court had deprived him of his right to due process under the federal constitution by denying his motion to suppress a one-on-one showup identification of him by a restaurant employee. See State v. McLaurin, 216 Conn. App. 449, 466, 285 A.3d 104 (2022). The Appellate Court affirmed the trial court’s judgment of conviction, concluding that the exigencies of the investigation justified the police’s use of the showup identification procedure and, therefore, that the identification was not unnecessarily suggestive. See id., 466, 470, 479. We granted the defendant’s petition for certification to appeal, limited to the issue of whether the Appellate Court properly upheld the trial court’s denial of his motion to suppress. See State v. McLaurin, 346 Conn. 903, 287 A.3d 136 (2023). We affirm the judgment of the Appellate Court and conclude that the defendant’s constitutional right to due process was not violated because, even if the identification procedure was unnecessarily suggestive, the identification was reliable.")

• SC20785 Dissent - State v. McLaurin

SC20883 - State v. Traynham ("The defendant, Rickey Traynham, in collaboration with his accomplice, Jordan Rudel, conspired to rob the victim, Rondell Atkinson. After telling the victim that they would pay him for a ride in his vehicle, the defendant and Rudel forced the victim to drive to a park in Woodbridge. Upon arriving at the park, the defendant and Rudel ordered the victim out of the car and took his wallet, watch, and cell phone. Both men then brandished firearms and each shot the victim, fatally wounding him. After the shooting, Rudel confided in two people about what he and the defendant had done to the victim: Adrianna Santiago, his then girlfriend and the mother of his children; and Monique Jackson, his father’s longtime girlfriend. In the present case, the trial court permitted the state to introduce Rudel’s statements to Santiago and Jackson into evidence against the defendant as dual inculpatory statements under the statement against penal interest exception to the hearsay rule.

The sole issue in this direct appeal is whether the trial court improperly allowed the testimony from Santiago and Jackson as dual inculpatory statements under the statement against penal interest exception to the hearsay rule. Because Rudel’s statements were indisputably against his penal interest and were sufficiently trustworthy, we affirm the judgment of the trial court.")

• Posted in:
• Constitutional Law,
• Criminal Law & Procedure,
• Recent Opinions

SC20856 - State v. Bolton ("The principal issue in this appeal requires us to consider how a trial court should exercise its discretion when addressing, pursuant to Practice Book § 42-31, a juror’s equivocation during a jury poll . The defendant, John Bolton, raises three claims on appeal from the judgment of conviction of murder in violation of General Statutes § 53a-54a (a) and criminal possession of a firearm in violation of General Statutes (Rev. to 2019) § 53a-217 (a) (1). First, he claims that the trial court abused its discretion when it denied his motion for a mistrial following its decision to stop polling the jury when a juror reported her disagreement with the verdict. Second, he claims that the trial court’s response to the juror’s equivocation resulted in a coerced verdict. Third, he claims that the trial court failed to comply with Practice Book § 42-31 when it stopped polling the jury. We disagree with each of the defendant’s claims and affirm the judgment of conviction.")

AC47032 - State v. DeAngelo ("The defendant, Christopher DeAngelo, as an acquittee, appeals from the judgment of the trial court granting the state’s petition to continue commitment (petition) to the jurisdiction of the Psychiatric Security Review Board (board) for an additional period of five years. The dispositive issue in this appeal is whether the court properly determined that the state met its burden of proving by clear and convincing evidence that the defendant, after serving his maximum term of commitment, presently constitutes a danger to himself or others. See, e.g., State v. Torell, 223 Conn. App. 21, 38, 307 A.3d 280 (2023), cert. denied, 348 Conn. 960, 312 A.3d 36 (2024). On the basis of our thorough review of the record in this matter, we determine that there is no support for the court’s conclusion that the state met its heightened burden and, therefore, that the court improperly granted the state’s petition. Accordingly, we reverse the judgment of the trial court and remand the case with direction to deny the state’s petition for the defendant’s continued commitment to the jurisdiction of the board.")

• Posted in:
• Criminal Law & Procedure,
• Recent Opinions