State v. Angel A. (Dissent)

CourtConnecticut Appellate Court
DecidedOctober 7, 2025
DocketAC47294
StatusPublished

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

Bluebook
State v. Angel A. (Dissent), (Colo. Ct. App. 2025).

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

2 ,0 0 Conn. App. 0 State v. Angel A.

MOLL, J., dissenting. The crux of this appeal involves the right of the defendant, Angel A.—having just been found guilty of, inter alia, attempt to commit murder in violation of General Statutes §§ 53a-49 (a) (2) and 53a-54a (for which he subsequently received a consecu- tive sentence of twenty years of incarceration)—to have the jury polled pursuant to Practice Book § 42-31,1 which, ‘‘although not of constitutional dimension, is nonetheless a corollary to the defendant’s right to a unanimous verdict.’’ (Internal quotation marks omit- ted.) State v. Pare, 253 Conn. 611, 623, 755 A.2d 180 (2000). Our Supreme Court has held that, in a criminal case, a trial court’s failure to conduct a jury poll follow- ing a timely request constitutes structural error2 not subject to harmless error review.3 See id., 635–39. In the present case, one juror, C.A., purportedly told the trial judge in the jury deliberation room—after the return of the verdict but before the jury had been dis- charged—that she ‘‘[felt] a little guilty about the attempted murder charge.’’4 The court did not advise 1 Practice Book § 42-31 provides: ‘‘After a verdict has been returned and before the jury has been discharged, the jury shall be polled at the request of any party or upon the judicial authority’s own motion. The poll shall be conducted by the clerk of the court by asking each juror individually whether the verdict announced is such juror’s verdict. If upon the poll there is not unanimous concurrence, the jury may be directed to retire for further deliberations or it may be discharged.’’ (Emphasis added.) 2 A structural error is ‘‘a defect affecting the framework within which the trial proceeds, rather than simply an error in the trial process itself. . . . Such errors infect the entire trial process . . . .’’ (Internal quotation marks omitted.) State v. Lopez, 271 Conn. 724, 733, 859 A.2d 898 (2004). 3 In contrast, in a civil case, a violation of Practice Book § 16-32—the civil counterpart of Practice Book § 42-31—is subject to harmless error review. See Wiseman v. Armstrong, 295 Conn. 94, 115, 989 A.2d 1027 (2010). 4 It does not appear from the December 5, 2018 transcript (the date of the verdict and the discharge of the jury) that the trial judge informed counsel that she intended to speak with the jurors following their exit from the courtroom. See Tessmann v. Tiger Lee Construction Co., 228 Conn. 42, 57, 634 A.2d 870 (1993) (‘‘[a]nswering jurors’ questions, to promote good public relations, and soliciting feedback regarding the performance of mem- bers of the bar are within the court’s administrative functions and are permissible under [the rule of the Code of Judicial Conduct governing ex 0, 0 CONNECTICUT LAW JOURNAL Page 1

0 Conn. App. 0 ,0 3 State v. Angel A.

counsel of C.A.’s statement prior to the jury’s separation and dispersal. In my view, it is inconceivable that, had he immedi- ately been informed of C.A.’s statement, defense coun- sel would not have made a polling request prior to the jury’s discharge (i.e., at a time when such request would have been deemed timely as a matter of law pursuant to State v. Pare, supra, 253 Conn. 611, and when the court would have been required to conduct a poll). See id., 621 (‘‘We conclude that, pursuant to [Practice Book] § 42-31, a trial court’s obligation to poll the jury upon a timely request from either party is mandatory. We conclude further that a jury is not discharged for the purpose of § 42-31 until its individual members separate or disperse and, therefore, a request submitted prior thereto is timely.’’). Because I see no meaningful differ- ence between a trial court’s per se reversible denial of a request to conduct a jury poll following a timely request, as in Pare, and a trial court’s withholding of information that otherwise would have prompted a timely request for a jury poll, as in the present case, I respectfully dissent from part I of the majority opinion and would reverse the judgment of conviction of attempt to commit murder and remand the case for a new trial on that count.5 As a threshold matter, I disagree with the majority’s analysis in part I concerning the issue of preservation of the defendant’s first claim on appeal. Unlike the majority, I would deem the defendant’s claim pre- served.6 parte communications] as long as the judge fully discloses [her] intention to speak with the jury and discloses the subject matter to be discussed’’ (emphasis added)). The defendant does not raise this issue on appeal. 5 As the majority correctly notes, on appeal, the defendant seeks a reversal of the judgment of conviction only as to the count of attempt to commit mur- der. 6 The majority concludes that the defendant did not preserve his Practice Book § 42-31 claim because he did not raise it (1) during the posttrial hearing or (2) in a motion for a new trial. With regard to the former (i.e., that the Page 2 CONNECTICUT LAW JOURNAL 0, 0

4 ,0 0 Conn. App. 0 State v. Angel A.

Practice Book § 60-5 provides in relevant part that this court ‘‘shall not be bound to consider a claim unless it was distinctly raised at the trial or arose subsequent to the trial. . . .’’ (Emphasis added.) See Weiss v. Smulders, 313 Conn. 227, 247–48, 96 A.3d 1175 (2014) (because issue arose subsequent to trial, claim on appeal was deemed preserved); Azia v. DiLascia, 64 Conn. App. 540, 558–59 n.13, 780 A.2d 992 (same), cert. denied, 258 Conn. 914, 782 A.2d 1241 (2001); Hayward v. Hayward, 53 Conn. App. 1, 5–6, 752 A.2d 1087 (1999) (same). Here, the issue of C.A.’s equivocation as to the verdict arose—from the perspective of the parties’ knowl- edge—subsequent to the trial (more specifically, after defendant did not raise this claim during the posttrial hearing), by the time of that hearing, a request for an individual poll under Practice Book § 42- 31 would have been too late as a matter of law, through no fault of the defendant. See State v. Pare, supra, 253 Conn. 632–33. With regard to the latter (i.e., that the defendant did not raise the issue in a motion for a new trial), the majority cites State v. Franklin, 162 Conn. App. 78, 93, 129 A.3d 770 (2015), cert.

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Bluebook (online)
State v. Angel A. (Dissent), Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-angel-a-dissent-connappct-2025.