State v. Angel A.

Supreme Court of Connecticut·Decided September 8, 2026·No. SC21180·Published

Opinion

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STATE OF CONNECTICUT v. ANGEL A.* (SC 21180)

Mullins, C. J., and McDonald, D’Auria, Ecker, Alexander, Dannehy and Bright, Js.**

Syllabus

The defendant appealed, on the granting of certification, from the judgment of the Appellate Court, which had affirmed his conviction of attempt to commit murder, among other crimes. After the jury foreperson announced the guilty verdict and the other jurors collectively indicated their agreement with that verdict, the trial judge informed the jurors that their jury service had ended and that they were “free from [their] oath at [that] point,” but asked that they return to the jury room. Shortly thereafter, the judge entered the jury room and indicated that she was there to answer any questions the jurors may have had about the trial or the court system in general but that she did not want to discuss their verdict or anything about their deliberations. After approximately five to seven minutes, one of the jurors, C.A., stated that she felt “a little guilty about the attempted murder charge” but did not indicate why she felt that way, and the judge did not ask C.A. any questions about her comment. Two days later, the judge disclosed C.A.’s remark to trial counsel and scheduled a hearing for the purpose of questioning C.A. At that hearing, the judge asked C.A. whether she said “yes” when she was asked by the court clerk if she had agreed with the verdict as reported by the foreperson. C.A. replied that she “absolutely did [say yes].” Defense counsel did not request that the jury be polled or raise any claim concerning jury unanimity at the hearing. On appeal to this court, the defendant claimed that the Appellate Court improperly upheld his conviction on the grounds that the trial court had violated his right to poll the jurors in accordance with the rules of practice (§ 42-31) and violated his constitutional right to a unanimous jury verdict. Held:

Contrary to the defendant’s claims, the trial court did not violate his rights to poll the jury or to a unanimous jury verdict, and, accordingly, this court affirmed the Appellate Court’s judgment.

The trial court’s failure to immediately disclose C.A.’s remark to trial counsel did not result in a violation of the defendant’s right to poll the jury under Practice Book § 42-31.

*

In accordance with federal law; see 18 U.S.C. § 2265 (d) (3) (2024); we decline to identify any person protected or sought to be protected under a protection order, protective order, or a restraining order that was issued or applied for, or others through whom that person’s identity may be ascertained.

**

The listing of justices reflects their seniority status on this court as of the date of oral argument.

The defendant’s polling claim arguably was not preserved because defense counsel never requested that the jury be polled, and an unpreserved claim alleging a violation of a defendant’s right to poll the jury is not reviewable under State v. Golding (213 Conn. 233), as modified by In re Yasiel R. (317 Conn. 773), because that right is not of constitutional dimension. Nonetheless, this court concluded that the defendant’s polling claim was reviewable under the rules of practice (§ 60-5), that claim having arisen “subsequent to [the defendant’s] trial” for purposes of Practice Book § 60-5 insofar as C.A. made her remark after the jury returned its verdict.

Under the express language of Practice Book § 42-31, a request to poll the jury is timely only if it is made after the jury has returned its verdict but before the jury has been discharged, and the purpose of that requirement is to guarantee the reliability of the jurors’ responses to the poll by ensuring that the jury remains under the trial court’s control, untainted by outside contact, and without an opportunity to discuss the case with others.

In the present case, even if the trial judge had immediately disclosed C.A.’s remark to the parties, the jurors could not have been polled because they already had been discharged when C.A. made her remark, and the jurors had no reason to believe that they remained under the trial court’s supervision , that any other obligations were imposed on them by their oaths, or that they were still bound by the court’s instructions that they, inter alia, refrain from discussing the case, from performing research about the case, and from reviewing outside information and media reports about the case.

Although there was no way of knowing what occurred immediately after the jury delivered its verdict and went back to the jury room, in the absence of evidence to the contrary, it was reasonable to believe that the jurors had the opportunity to initiate or receive outside communications, even before the trial judge entered the room, and, because even seemingly innocuous interactions with an outsider can influence a juror’s views about a case, the postverdict, ex parte communication between the trial judge and the jury in the present case called into doubt the reliability of any poll that would have been conducted thereafter.

The trial court did not violate the defendant’s constitutional right to a unanimous jury verdict by failing to immediately disclose C.A.’s remark to trial counsel, the defendant having failed to demonstrate the existence of a constitutional violation for purposes of the third prong of Golding, as modified by In re Yasiel R.

C.A.’s remark did not implicate any claim about jury unanimity, and the present case did not involve any risk that the trial court had permitted or accepted a nonunanimous jury verdict, as C.A.’s remark that she felt “a little guilty about the attempted murder charge” did not express any uncertainty or equivocation about her decision to find the defendant guilty of attempt to commit murder.

Rather, jury deliberations may arouse strong and unsettling emotions for jurors in light of the grave consequences that a guilty verdict will have on a defendant, and C.A.’s remark was consistent with the notion that she had agreed with the verdict but felt some concern about the impact that the guilty verdict would have on the defendant.

Moreover, at the time C.A. made her remark, there was no indication that she disagreed with the verdict, and she emphasized at the posttrial hearing that she “absolutely did” agree with the verdict when the foreperson announced it in court.

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