State v. Bolden

227 Conn. App. 636
CourtConnecticut Appellate Court
DecidedAugust 27, 2024
DocketAC46215
StatusPublished
Cited by1 cases

This text of 227 Conn. App. 636 (State v. Bolden) 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. Bolden, 227 Conn. App. 636 (Colo. Ct. App. 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

2 ,0 0 Conn. App. 1 State v. Bolden

STATE OF CONNECTICUT v. CHRISTOPHER BOLDEN (AC 46215) Elgo, Moll and Prescott, Js.

Syllabus

Pursuant to statute (§ 53a-155 (a)), a defendant is guilty of tampering with evidence if, ‘‘believing that a criminal investigation conducted by a law enforcement agency . . . is . . . about to be instituted, [the defendant] . . . conceals . . . [a] thing with purpose to impair its . . . availability in such criminal investigation . . . .’’ Convicted, following a jury trial, of the crimes of evading responsibility in the operation of a motor vehicle and tampering with physical evidence, the defendant appealed to this court. The defendant’s conviction stemmed from an incident during which the defendant struck and killed the victim with the SUV he was driving, fled the scene, and thereafter left the SUV in a driveway. Held: 1. The defendant could not prevail on his claim that the evidence was insufficient to support his conviction of tampering with evidence: a. The evidence was sufficient to prove beyond a reasonable doubt that the defendant believed that a criminal investigation was about to be instituted when he fled the scene of the accident and abandoned the SUV he was driving in a driveway; the jury was permitted to consider circumstantial evidence presented by the state to make reasonable infer- ences regarding the defendant’s state of mind, including evidence that the defendant saw the victim on the ground when he returned to the intersection before fleeing the scene, or that the defendant must have known from the significant damage to the SUV that the victim had been injured, and the jury was free to credit or discredit the defendant’s statements in his recorded statement to the police. b. There was sufficient evidence to prove beyond a reasonable doubt that the defendant had concealed the SUV; a rational juror could consider and credit the context for the defendant’s act of concealment, including evidence that the defendant likely knew he had seriously injured a pedes- trian, fled the scene, and needed to act quickly and temporarily abandon the vehicle, which had become disabled, and, in light of the defendant’s exigent circumstances, a juror could conclude that he saw an opportunity to make the SUV less noticeable in a private driveway among several other vehicles. 2. This court did not reach the merits of the defendant’s claim that the trial court’s refusal to answer two questions submitted by the jury during its deliberations as to whether moving evidence equated to tampering or concealing evidence resulted in an unconstitutional enlargement of the charged crimes, as that claim was deemed waived pursuant to State 0, 0 CONNECTICUT LAW JOURNAL Page 1

0 Conn. App. 1 ,0 3 State v. Bolden v. Kitchens (299 Conn. 447): although the trial court did not inform the parties of the answer it intended to provide to the jury’s questions, it invited counsel, outside the presence of the jury, to raise any issues before the answer was given, both counsel stated that they had nothing further to discuss, and counsel failed to object after the court responded to the jury’s questions; accordingly, this court could not say that the defendant was deprived of a fair trial when the record indicated that the defense was provided a meaningful opportunity to propose an answer to the jury’s questions and to object to the trial court’s response to those questions, and, therefore, the defendant waived the right to chal- lenge that response on appeal. Argued May 15—officially released August 27, 2024

Procedural History

Substitute information charging the defendant with the crimes of evading responsibility in the operation of a motor vehicle, misconduct with a motor vehicle, and tampering with physical evidence, brought to the Supe- rior Court in the judicial district of Waterbury, geo- graphical area number four, and transferred to the judi- cial district of Waterbury, where the case was tried to the jury before Kwak, J.; verdict and judgment of guilty of evading responsibility in the operation of a motor vehicle and tampering with physical evidence, from which the defendant appealed to this court. Affirmed. Alice Osedach Powers, assigned counsel, for the appellant (defendant). Alexander O. Kosakowski, certified legal intern, with whom were Scott A. Warden, certified legal intern, and, on the brief, Ronald G. Weller, senior assistant state’s attorney, for the appellee (state). Opinion

ELGO, J. The defendant, Christopher Bolden, appeals from the judgment of conviction, rendered following a jury trial, of evading responsibility in the operation of a motor vehicle in violation of General Statutes § 14-224 (a) and tampering with physical evidence in violation of General Statutes § 53a-155 (a). On appeal, the defendant Page 2 CONNECTICUT LAW JOURNAL 0, 0

4 ,0 0 Conn. App. 1 State v. Bolden

claims that (1) with regard to the tampering charge, the evidence was insufficient to prove beyond a reasonable doubt that the defendant believed that a criminal inves- tigation was about to be instituted and that he had concealed a thing with the purpose to impair its avail- ability in such investigation, and (2) the court’s refusal to answer the jury’s questions during its deliberations resulted in an improper enlargement of the charged crimes. We disagree and, accordingly, affirm the judg- ment of the trial court. The following facts, as reasonably could have been found by the jury, are relevant to the resolution of this appeal. At approximately 8:40 p.m. on May 1, 2020, the defendant, an unlicensed driver, was driving his girlfriend’s black BMW sport utility vehicle (SUV) on Baldwin Street in Waterbury. The roadway was dry, and the intersection of Baldwin Street and Scovill Street was well lit from the streetlights and exterior lights from Saint Mary’s Hospital. A witness driving a vehicle behind the defendant could clearly see the victim, Sha- neice Copeland, walking along the sidewalk near the intersection. As the defendant and the witness both approached the intersection, the light was green. At that time, the victim stepped off the sidewalk and into the crosswalk. The defendant did not slow down or brake as he approached the intersection, and he struck the victim with the SUV. The victim rolled over the hood of the SUV before landing on the street. After striking the victim, the defendant drove several hundred feet before coming to a stop on Baldwin Street.

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Related

State v. Bolden
353 Conn. 769 (Supreme Court of Connecticut, 2025)

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Bluebook (online)
227 Conn. App. 636, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-bolden-connappct-2024.