State v. Guerrero

Supreme Court of Connecticut·Decided September 8, 2026·No. SC21059·Published

Opinion

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STATE OF CONNECTICUT v. LEON L. GUERRERO (SC 21059)

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

Syllabus

Convicted, after a jury trial, of murder in connection with the shooting death of the victim, the defendant appealed. The shooting arose from a verbal exchange and physical altercation involving the defendant, F and M. During an argument in which the defendant and F exchanged insults, the defendant indicated that he had a gun in his car, which was parked nearby. The defendant and F began fighting. M then attempted to break up the fight, and the defendant challenged M to fight. Both F and M tried to leave in their car, but the defendant engaged them further, and a melee involving the defendant, F and M ensued. At some point, the defendant retrieved his gun, and then others, including the victim, arrived on the scene, ran toward the melee, and, as they got close, the defendant fired his gun. The bullet ultimately struck the victim and killer her. At the defendant’s probable cause hearing, at which the state called M to testify, M invoked his privilege against self-incrimination, and the state granted M immunity in exchange for his testimony and sought an order to compel him to testify pursuant to statute (§ 54-47a). The trial court granted the state’s request and ordered M to testify, but defense counsel withdrew his request for a probable cause hearing before any testimony was presented. To ensure that M would testify for the state at the defendant’s criminal trial, M was arrested pursuant to a material witness warrant. M ultimately testified against the defendant after being granted immunity. At trial, the defendant sought to establish a claim of self-defense, but the jury rejected that claim and found him guilty of murder under a transferred intent theory. On appeal, the defendant claimed, inter alia, that the state had failed to meet its burden of proving beyond a reasonable doubt that the provocation exception to self-defense defeated his self-defense claim and that the prosecutor had engaged in certain prosecutorial improprieties. Held:

Because the evidence in the record was sufficient for the jury to have found that the defendant did not reasonably believe that deadly physical force was necessary to defend himself, the defendant’s self-defense claim was unavailing, and, therefore, it was not necessary for the state to prove that the provocation exception, or any other exception, to self-defense applied in order to secure the defendant’s murder conviction.

The jury reasonably could have found that any belief the defendant had that deadly force was necessary to defend himself was unreasonable in light of the evidence adduced at trial, including that neither M nor F was armed with a weapon, there was no indication to the defendant that M or F was armed, and * The listing of justices reflects their seniority status on this court as of the date of oral argument.

neither M nor F ever attempted to use deadly force against the defendant or to inflict great bodily harm on him.

The prosecutor did not engage in prosecutorial impropriety that deprived the defendant of his due process right to a fair trial when, during rebuttal argument, he stated to the jury that M was reluctant to testify against the defendant because of a purported familial connection to the defendant, specifically, that the defendant was the biological father of L, a child whom M considered to be his stepdaughter.

The prosecutor’s remark regarding M’s reluctance to testify did not improperly rely on facts not in evidence, as the jury heard testimony that M was reluctant to testify because of L and her relationship to the defendant.

Moreover, the prosecutor’s remark regarding M’s reluctance to testify did not constitute a personal opinion concerning M’s credibility, as the prosecutor neither vouched for M’s credibility nor implied that he had outside knowledge thereof, and, immediately prior to the challenged remark, the prosecutor informed the jury that it was the arbiter of witness credibility.

Furthermore, the prosecutor did not improperly appeal to the emotions, passions , and prejudices of the jurors when he referred to the familial relationship between M and L, as the prosecutor did not attempt to gain sympathy for M by lingering on his relationship with L or by contending that M must be a great stepfather because he did not want to testify against L’s biological father but, rather, sought to encourage the jurors to consider the testimony M gave regarding his reluctance to testify and to assess his credibility on the basis of that testimony.

The defendant could not prevail on his claim that the prosecutor, through a series of evidentiary maneuvers that prevented defense counsel from asking M about his prior invocation of his privilege against self-incrimination, improperly misled the jury regarding M’s reluctance to testify against the defendant and, therefore, had a duty to correct M’s testimony.

There was no evidence to suggest that M’s testimony regarding his concern for L was false, and, although defense counsel was barred from questioning M about his invocation of the privilege against self-incrimination, counsel was not prohibited from eliciting testimony from M that his prior reluctance to testify was attributable to his fear of exposure to criminal liability in connection with the altercation that resulted in the victim’s death.

In addition, because M, in exchange for his testimony, was afforded immunity that shielded him from prosecution related to the victim’s death, it was unlikely that M’s reluctance to testify against the defendant was due to his concern about future criminal charges rather than because of his connection to the defendant through L.

Argued March 6—officially released September 8, 2026

Procedural History

Substitute information charging the defendant with the crime of murder, brought to the Superior Court in the judicial district of New Haven and tried to the jury before Vitale, J.; verdict and judgment of guilty, from which the defendant appealed. Affirmed.

Norman A. Pattis, for the appellant (defendant). Meryl R. Gersz, assistant state’s attorney, with whom, on the brief, were John Doyle, Jr., state’s attorney, and Gregory L. Borrelli and Melissa Holmes, senior assistant state’s attorneys, for the appellee (state).

Opinion

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