State v. Brown

CourtSupreme Court of Connecticut
DecidedMay 19, 2026
DocketSC20964
StatusPublished

This text of State v. Brown (State v. Brown) 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. Brown, (Colo. 2026).

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 postopinion motions and petitions for certification is the “officially 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 Connecticut 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 Journal 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. ************************************************ State v. Brown

STATE OF CONNECTICUT v. JAMES BROWN (SC 20964)

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

Syllabus

Convicted of murder in connection with the shooting death of the victim, the defendant appealed to this court. The shooting had occurred amid a fight between two rival groups with which the defendant and the victim, respectively, were affiliated. At trial, the clerk of the court informed the court that one of the jurors, Juror 7, had expressed concerns for her safety stemming from certain interactions with a trial attendee. After discussing the incident with counsel and canvassing both Juror 7, who denied having or expressing any such safety concerns, and the clerk, the court excused Juror 7 from the jury. The court then canvassed the remaining jurors. One of the remaining jurors, Juror 1, indicated that he had overheard Juror 7 raise safety concerns and that two other jurors, Jurors 3 and 6, had also overheard those concerns, but all of the other remaining jurors denied having or overhearing any conversations regarding concerns about the trial. Thereafter, defense counsel moved for a mistrial, contending that the canvass process itself made it impossible for the remaining jurors to be fair and impartial and that Jurors 1, 3 and 6 also should have been excused. The trial court denied that motion. On appeal, the defendant claimed, inter alia, that the trial court had abused its discretion when it declined to declare a mistrial. Held:

The trial court did not abuse its discretion in denying defense counsel’s motion for a mistrial and excusing only Juror 7 from the jury.

The defendant was not entitled to a presumption, pursuant to Remmer v. United States (347 U.S. 227), that the allegedly improper interaction involv- ing Juror 7 was prejudicial.

That presumption of prejudice applies only when some external interference with the jury’s deliberative process via private communication, contact, or tampering with jurors relates directly to the matter being tried.

In the present case, the defense failed to demonstrate that the allegedly improper juror contact pertained directly to the merits of the matter rather than to the trial more topically.

The only inference of interference or tampering that the defense adduced was that Juror 7 believed that one or more trial attendees watched her walk to her car, before or after one of those attendees commented on her coat, Juror 7 later denied ever having or expressing any concerns about her safety when canvassed by the court, Juror 1 was the only juror who testified that Juror 7 had expressed such a concern, the trial court made no finding that threatening or intimidating conduct had occurred, and Juror 7 was excused because of her own conduct rather than because of any efforts at intimidation. State v. Brown

The trial court did not abuse its discretion when it declined to declare a mis- trial, as the court, in canvassing all of the jurors, effectively ascertained the nature and import of any potential juror bias, each juror was unequivocal about his or her ability to be fair and impartial, no other juror stated that he or she had safety concerns, and the court was able to observe the jurors’ answers to its questions and to assess their demeanor.

With respect to the defendant’s claim that the trial court should have excused Jurors 3 and 6, it was speculative for the defendant to claim that those jurors had safety concerns despite their unequivocal testimony to the contrary, and, even if there were nonspeculative reasons to believe that Jurors 3 and 6 harbored safety concerns, the trial court had the unique opportunity to observe those jurors and to make credibility determinations, which it did through a meticulous and exhaustive canvassing process.

With respect to the defendant’s claim that the trial court should have excused Juror 1 insofar as his statements that he did “[n]ot yet” have safety concerns and that nothing made him concerned “so far” were equivocal, those state- ments could reasonably be understood to communicate that, at the time of questioning, Juror 1 did not have any safety concerns, and there was noth- ing in the record to indicate that Juror 1 anticipated any such concerns in the future.

To the extent that the defendant contended that Juror 1 subjectively believed that the trial court cajoled him into disavowing his safety concerns, that argument was speculative and without merit.

The defendant could not prevail on his claim that the prosecutor’s question- ing of two witnesses, H and R, constituted prosecutorial impropriety that deprived him of his constitutional right to a fair trial.

No impropriety occurred when the prosecutor attempted to refresh H’s recollection with his disavowed sworn statement to the police and asked H whether he had authored a sentence containing “word on the street” hear- say indicating that the defendant was the person who had shot the victim.

The prosecutor’s ostensible purpose in asking about the hearsay was not to use it as substantive evidence but to lay a foundation for treating H as a hostile witness and to provide a basis for admitting H’s prior sworn state- ment, and, when the trial court ordered the prosecutor not to refer to that hearsay again, he complied with that order.

The prosecutor did not improperly appeal to the jurors’ emotions, passions, or prejudices when he asked R about the circumstances surrounding his arrest pursuant to a capias warrant.

Given that R had disavowed a prior sworn statement to the police in which he stated that he had witnessed the shooting of the victim, the prosecu- tor’s questioning was permissible to discredit R’s lack of recollection and to impeach R as someone who had changed his story to spread the word that he was not a snitch. State v. Brown

Moreover, defense counsel’s extensive cross-examination of R about the circumstances of his arrest suggested that defense counsel did not believe that the prosecutor’s line of questioning was improper.

Argued February 2—officially released May 19, 2026

Procedural History

Substitute information charging the defendant with the crime of murder, brought to the Superior Court in the judicial district of Hartford and tried to the jury before Droney, J.; verdict and judgment of guilty, from which the defendant appealed to this court. Affirmed. Denis J.

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Related

Remmer v. United States
347 U.S. 227 (Supreme Court, 1954)
State v. McLaren
15 A.3d 183 (Connecticut Appellate Court, 2011)
State v. Hughes
341 Conn. 387 (Supreme Court of Connecticut, 2021)
State v. Whelan
513 A.2d 86 (Supreme Court of Connecticut, 1986)
State v. Williams
529 A.2d 653 (Supreme Court of Connecticut, 1987)
State v. Warholic
897 A.2d 569 (Supreme Court of Connecticut, 2006)
State v. Garcia
509 A.2d 31 (Connecticut Appellate Court, 1986)
California v. Tyberg
479 U.S. 994 (Supreme Court, 1986)
State v. Sullivan
351 Conn. 798 (Supreme Court of Connecticut, 2025)

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State v. Brown, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-brown-conn-2026.