State v. Andres C. (Concurrence & Dissent)

CourtSupreme Court of Connecticut
DecidedJune 18, 2024
DocketSC20692
StatusPublished

This text of State v. Andres C. (Concurrence & Dissent) (State v. Andres C. (Concurrence & Dissent)) is published on Counsel Stack Legal Research, covering Supreme Court of Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Andres C. (Concurrence & Dissent), (Colo. 2024).

Opinion

************************************************ The “officially released” date that appears near the beginning of an opinion is the date the opinion will be published in the Connecticut Law Journal or the date it is released as a slip opinion. The operative date for the beginning of all time periods for the filing of postopin- ion motions and petitions for certification is the “offi- cially released” date appearing in the opinion. All opinions are subject to modification and technical correction prior to official publication in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports. In the event of discrepancies between the advance release version of an opinion and the version appearing in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports, the latest version is to be considered authoritative. The syllabus and procedural history accompanying an opinion that appear in the Connecticut Law Jour- nal and subsequently in the Connecticut Reports or Connecticut Appellate Reports are copyrighted by the Secretary of the State, State of Connecticut, and may not be reproduced or distributed without the express written permission of the Commission on Official Legal Publications, Judicial Branch, State of Connecticut. ************************************************ Page 0 CONNECTICUT LAW JOURNAL 0, 0

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D’AURIA, J., concurring in part and dissenting in part. When a court is presented with a case posing a unique set of facts amid a legal landscape that is not well developed, often, the most prudent course is to opt for a practical solution. This is such a case. And while I accept my share of responsibility for the delay in decid- ing this case, the most practical solution has always been right in front of us: remand the case to the trial court to order an official translation of the complain- ant’s journals from Spanish to English. This simple step is appropriate under our rules of practice, is supported by our own case law and case law from other courts, and would resolve an unusual dilemma sooner than awaiting a collateral proceeding, serving the interests of the complainant, the parties, and the judicial system. I do not understand the majority’s resistance to this commonsense solution, and I therefore respectfully dis- sent as to part II of the majority opinion. I concur with part I of the majority opinion except for footnote 10, with which I disagree and which, in my view, is not necessary to the opinion. I Prosecutors in the present case encountered a situa- tion that challenged their conventional obligations to disclose to the defendant, Andres C., any exculpatory or impeachment evidence in their exclusive possession. See generally Brady v. Maryland, 373 U.S. 83, 83 S. Ct. 1194, 10 L. Ed. 2d 215 (1963). The complainant, the state’s main witness, revealed for the first time during her redirect testimony that, at her therapist’s sugges- tion, she had kept journals that documented some of the defendant’s alleged abuse of her. That these journals promptly came into the state’s possession, which the state does not dispute, meant it had a duty to review them to determine if they contained Brady material. See, e.g., Strickler v. Greene, 527 U.S. 263, 278, 119 S. 0, 0 CONNECTICUT LAW JOURNAL Page 1

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Ct. 1936, 144 L. Ed. 2d 286 (1999) (pursuant to Brady, state must ‘‘disclose to the defense all exculpatory evi- dence known to it—or in its possession’’ (internal quota- tion marks omitted)); Peeler v. Commissioner of Correction, 170 Conn. App. 654, 700, 155 A.3d 772 (‘‘Brady requires the state to disclose all evidence in its exclusive possession that is favorable to the defen- dant and material. . . . Brady does not require the state to obtain and disclose evidence in the exclusive possession of a private, third party entity.’’ (Citation omitted.)), cert. denied, 325 Conn. 901, 157 A.3d 1146 (2017). As prosecutors sought to comply with their affirma- tive constitutional obligation under Brady, at least two problems confronted them. First, although Brady claims most often involve either pretrial or posttrial skirmishes over potentially exculpatory evidence, these journals came to light during the complainant’s testimony on the first day of trial. See United States v. Agurs, 427 U.S. 97, 103–107, 96 S. Ct. 2392, 49 L. Ed. 2d 342 (1976) (enumerating three circumstances in which Brady claims often arise, all occurring either before or after trial). Although the parties were trying the case to the court and not a jury, presumably, the court planned for the case to proceed apace. Second, the victim recorded her journals in Spanish, and the record does not reflect that any of the other participants in this trial spoke Spanish, or spoke it well enough to translate the journals in a way that would be useful to the state, the defendant, or the court.1 1 Another challenge to any review or use of the journals is that the com- plainant’s testimony suggested both that her journals were the ‘‘best record’’ of her allegations of the defendant’s abuse and also that, at her therapist’s request, she sometimes used these journals for therapeutic exercises that were hypothetical in nature. Therefore, she did not claim that the journals were necessarily in all instances accurate accounts of the abuse. For exam- ple, she testified: ‘‘[My therapist] would have me write a lot about either my relationship to [the defendant], with [the defendant], how the abuse happened. I would reflect a lot on how it made me feel, how I was missing, why I didn’t want to talk. Sometimes in the journal, we’d write about—like Page 2 CONNECTICUT LAW JOURNAL 0, 0

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Both the majority and the dissent detail sufficiently the procedure trial prosecutors undertook to have the complainant’s journals reviewed by an investigator in their office (reported to be bilingual), the limited disclo- sure made to defense counsel from the journals after that review, and the defendant’s claim concerning those journals on which the parties are at issue on appeal. I will not repeat how that issue has arrived before us. The majority concludes that ‘‘the prosecutor did not violate Brady by not personally reviewing the journals’’ but, instead, delegating2 that review to a subordinate. This conclusion leads the majority to reject the defen- dant’s calls to adopt a prophylactic rule requiring prose- cutors to personally review records that come to light during trial for Brady material and to hold that this if I was having family fights, so my journals are the abuse that I lived with him, but also family fights with my siblings and my mom.’’ The complainant also agreed with defense counsel when he asked her on cross-examination if the journals were her ‘‘words through therapy . . . .’’ 2 The majority eschews use of the word ‘‘delegate.’’ I do not understand its aversion to the word. I use the word ‘‘delegate’’ for two reasons. First, it is the word both the Appellate Court and the state use. Second, the euphemisms used to describe the prosecutors’ assignment of the chore of translating the journals to the investigator fail because they are inaccurate. Specifically, the prosecutors did not ‘‘enlist the assistance of a Spanish- speaking investigator on her staff to help review the journals.’’ (Emphasis added.) Nor did the prosecutors enlist the investigator ‘‘to assist in the review of records for potential Brady material.’’ (Emphasis added.) The investigator reviewed the journals. Period. The prosecutors did not.

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State v. Andres C. (Concurrence & Dissent), Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-andres-c-concurrence-dissent-conn-2024.