State v. Garrison

230 Conn. App. 820
CourtConnecticut Appellate Court
DecidedFebruary 25, 2025
DocketAC43796
StatusPublished

This text of 230 Conn. App. 820 (State v. Garrison) 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. Garrison, 230 Conn. App. 820 (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. 1 State v. Garrison

STATE OF CONNECTICUT v. ALEXANDER A. GARRISON (AC 43796) Moll, Suarez, and Prescott, Js. Syllabus Convicted of assault in the first degree, the defendant appealed. He claimed, inter alia, that the trial court improperly denied his motion to suppress certain statements he made to police officers while he was in a hospital receiving treatment for injuries he sustained in a physical altercation that led to his arrest and conviction. This court reversed the judgment of convic- tion and remanded the case for a new trial without addressing the other claims the defendant raised in his appeal. On the granting of certification, the state appealed to our Supreme Court, which determined that the defen- dant had not been in custody during any of his interactions with the police at the hospital and, therefore, his statements should not have been sup- pressed. The Supreme Court reversed the judgment of this court and remanded the case to this court with direction to consider the defendant’s remaining claims on appeal, including his claim that the admission of his statements to the police violated his right to due process. Held: The trial court did not improperly deny the defendant’s motion to suppress his statements to the police officers, as the state sufficiently demonstrated that the statements, under the totality of the circumstances, were voluntary and, thus, their admission at trial did not violate his right to due process. The trial court did not abuse its discretion in denying the defendant’s motion for sanctions against the state for its failure to comply with certain of the court’s discovery orders and its failure to disclose alleged impeachment evidence pursuant to Brady v. Maryland (373 U.S. 83) and Giglio v. United States (405 U.S. 150). This court declined the defendant’s request to exercise its supervisory authority over the administration of justice to direct trial courts to conduct a formal, on the record inquiry during pretrial hearings to ascertain whether the state has exercised due diligence in locating evidence favorable to defendants, as the defendant failed to demonstrate that this case presented the rare circumstance in which traditional constitutional, statutory and pro- cedural limitations were inadequate to protect the rights of the defendant and the integrity of the judicial system. Submitted on briefs October 7, 2024—officially released February 25, 2025

Procedural History

Information charging the defendant with the crimes of assault in the first degree and tampering with physical 0, 0 CONNECTICUT LAW JOURNAL Page 1

0 Conn. App. 1 ,0 3 State v. Garrison

evidence, brought to the Superior Court in the judicial district of Tolland, where the court, Bhatt, J., denied the defendant’s motion to suppress certain evidence; thereafter, the case was tried to the court, Seeley, J.; subsequently, the court, Seeley, J., granted the defen- dant’s motion for a judgment of acquittal as to the charge of tampering with physical evidence; judgment of guilty of assault in the first degree, from which the defendant appealed to this court, Prescott, Suarez and Bishop, Js., which reversed the trial court’s judgment and remanded the case for a new trial, from which the state, on the granting of certification, appealed to the Supreme Court, which reversed this court’s judgment and remanded the case to this court for further proceed- ings. Affirmed. Erica A. Barber filed a brief for the appellant (defen- dant). Matthew C. Gedansky, state’s attorney, and Sarah Hanna, former senior assistant state’s attorney, and Jaclyn Preville, supervisory assistant state’s attorney, filed a brief for the appellee (state). Opinion

PRESCOTT, J. This case returns to us on remand from our Supreme Court. In State v. Garrison, 213 Conn. App. 786, 278 A.3d 1085 (2022), rev’d, 350 Conn. 61, 323 A.3d 279 (2024), the defendant, Alexander A. Garrison, appealed from the judgment of conviction, rendered after a bench trial, of assault in the first degree in viola- tion of General Statutes § 53a-59 (a) (1). On appeal, the defendant claimed, inter alia, that the trial court improperly denied his motion to suppress statements he made to police officers while at a hospital because those statements were the result of a custodial interro- gation and he had not been advised of his rights pursu- ant to Miranda v. Arizona, 384 U.S. 436, 478–79, 86 S. Ct. 1602, 16 L. Ed. 2d 694 (1966). State v. Garrison, Page 2 CONNECTICUT LAW JOURNAL 0, 0

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

supra, 789–90. We agreed with the defendant and further concluded that he was harmed by the admission of these statements. Id., 790. Accordingly, we reversed the judgment of conviction and remanded the case for a new trial without addressing the other claims raised by the defendant in his appeal. See id., 790 n.1. After granting the state’s petition for certification to appeal, our Supreme Court reversed the judgment of this court. State v. Garrison, 350 Conn. 61, 63, 323 A.3d 279 (2024). Specifically, it determined that the defendant was not in custody during any of his interac- tions with the police at the hospital, and, therefore, his statements made at that time should not have been suppressed. Id. Our Supreme Court then ordered us to consider on remand the defendant’s remaining appel- late claims. The remaining issues on appeal are whether the trial court improperly denied (1) the defendant’s motion to suppress because, contrary to the determination of the court, his statements to the police were not voluntary, and therefore their admission at trial violated his right to due process, and (2) his motion for sanctions in which he claimed that the state had failed to comply with the court’s discovery orders and its constitutional obligation to disclose impeachment evidence pursuant to Brady v. Maryland, 373 U.S. 83, 87, 83 S. Ct. 1194, 10 L. Ed. 2d 215 (1963).

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Bluebook (online)
230 Conn. App. 820, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-garrison-connappct-2025.