State v. Maharg

352 Conn. 355
CourtSupreme Court of Connecticut
DecidedJuly 8, 2025
DocketSC20855
StatusPublished

This text of 352 Conn. 355 (State v. Maharg) 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. Maharg, 352 Conn. 355 (Colo. 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. 1 State v. Maharg

STATE OF CONNECTICUT v. JAMES MAHARG (SC 20855) Mullins, C. J., and McDonald, D’Auria, Ecker, Alexander, Dannehy and Bright, Js.

Syllabus

Convicted, after a trial to a three judge panel, of murder and tampering with or fabricating physical evidence, the defendant appealed to this court. The trial court had suppressed certain statements the defendant made to the police during a station house interrogation, including the defendant’s confes- sion that he had killed the victim, on the ground that those statements were not voluntarily made. The trial court, however, declined to suppress certain other statements the defendant had made after the station house interroga- tion ended and while he was in the hospital, including another confession that he had killed the victim, on the ground that those statements were spontaneous and freely made. On appeal, the defendant claimed, inter alia, that he was deprived of his federal and state constitutional rights to due process and against self-incrimination because, although the trial court had properly suppressed his station house statements, the prosecutor improperly relied on those statements in securing his murder conviction. The defendant also claimed that the admission into evidence of his hospital statements violated his constitutional right to due process because those statements were a product of the station house interrogation and confession. Held:

The defendant’s unpreserved claim that the prosecutor and the trial court had improperly relied on his station house statements in securing his murder conviction and in finding the defendant guilty, respectively, failed under the first prong of State v. Golding (213 Conn. 233), as the record was inadequate for this court’s review of that claim.

The defendant’s claim was premised on the argument that, to develop their own opinions, three experts who testified at trial, two for the state and one for the defendant, relied in part on an investigative report prepared by the Office of the Chief Medical Examiner (OCME) that referred to the suppressed station house confession, but the defendant failed to demonstrate that the state’s experts knew of or had reviewed the OCME report in reaching the conclusions about which they respectively testified, and the defendant also failed to demonstrate, with respect to all three experts, that the references to the station house confession contained in the OCME report affected or influenced their respective findings and testimony.

Even if the trial court improperly admitted into evidence the statements that the defendant had made while he was in the hospital, any error was harmless, as those statements did not materially impact the court or the result of the trial because the court did not rely on them in reaching its 0, 0 CONNECTICUT LAW JOURNAL Page 1

0 Conn. 1 ,0 3 State v. Maharg conclusions, and, thus, the court would have found the defendant guilty beyond a reasonable doubt in the absence of those statements. (Three justices concurring in one opinion) Argued March 10—officially released July 8, 2025

Procedural History

Information charging the defendant with the crimes of murder and tampering with or fabricating physical evidence, brought to the Superior Court in the judicial district of Danbury, geographical area number three, and tried to a three judge panel, Pavia, Dayton and Medina, Js.; thereafter, the court granted in part and denied in part the defendant’s motion to suppress cer- tain evidence; finding and judgment of guilty, from which the defendant appealed to this court. Affirmed. Eric Del Pozo, with whom were Joette Katz and Eliz- abeth H. Buchanan, for the appellant (defendant). Laurie N. Feldman, assistant state’s attorney, with whom were Deborah Mabbett, supervisory assistant state’s attorney, and, on the brief, David R. Applegate, state’s attorney, and Mary-Caitlin E. Harding, assis- tant state’s attorney, for the appellee (state). Opinion

MULLINS, C. J. Following a bench trial before a three judge panel, the defendant, James Maharg, was found guilty of murdering his husband, Thomas Conley, in violation of General Statutes § 53a-54a (a). In connec- tion with the murder, the trial court also found him guilty of tampering with or fabricating physical evi- dence in violation of General Statutes § 53a-155. On appeal, the defendant raises two claims, challenging only his murder conviction. The defendant does not challenge his conviction of tampering with or fabricat- ing physical evidence. First, the defendant claims on appeal that he was deprived of his federal and state constitutional rights Page 2 CONNECTICUT LAW JOURNAL 0, 0

4 ,0 0 Conn. 1 State v. Maharg

to due process and against self-incrimination because, notwithstanding the fact that the trial court properly suppressed statements he had made during an almost thirteen hour police interrogation, including his confes- sion that he murdered Conley with a hatchet,1 the prose- cutor and the court extensively relied on those statements in bringing about his conviction of murder. He further asserts that the three experts who testified at trial relied on an investigative report by the Office of the Chief Medical Examiner (OCME report) that referred to the suppressed confession to develop their expert reports and findings, rendering the defendant’s trial fundamentally unfair.

Second, the defendant claims that the trial court erred in admitting statements he had made while in the emer- gency room, in which he confessed to the murder. He argues that, because those statements were made shortly after, and were a product of, his earlier, involun- tary confession, the taint from that earlier confession carried over and rendered his hospital confession equally involuntary and violative of due process. We reject both claims. Accordingly, we affirm the judgment of the trial court.

The trial court found, or reasonably could have found, the following facts. On March 20, 2019, at approximately 2 a.m., the defendant frantically called 911, and, after he was connected to a dispatcher, he yelled: ‘‘My hus- band is dead! My husband is dead!’’ The defendant relayed the following story to the dispatcher. He explained that he and Conley had been drinking a great deal through- 1 The police discovered both a hatchet and an axe during a sweep of the defendant’s property.

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Related

Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
United States v. Ralph Miller
800 F.2d 129 (Seventh Circuit, 1986)
Ghiroli v. Ghiroli
439 A.2d 1024 (Supreme Court of Connecticut, 1981)
State v. Velazquez
197 Conn. App. 754 (Connecticut Appellate Court, 2020)
State v. Armadore
338 Conn. 407 (Supreme Court of Connecticut, 2021)
State v. Golding
567 A.2d 823 (Supreme Court of Connecticut, 1989)

Cite This Page — Counsel Stack

Bluebook (online)
352 Conn. 355, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-maharg-conn-2025.