State v. Adams, 173 A.3d 943

On Sept. 23, 2006, Adams was observed on Marshalls’ surveillance video acting furtively: hiding behind a display, carrying merchandise, putting items into a plastic bag, and later leaving the store toward the exit without paying.
Loss prevention officers (Fernandes and Nates) confronted him; a brief scuffle occurred, they recovered a bag, and Adams fled.
The officers were unavailable at trial; Officer Pastrana testified that the officers told him they had “ran up” the bag’s contents at approximately $979.
At trial (2014) the court convicted Adams of attempted sixth‑degree larceny and second‑degree breach of the peace; the Appellate Court affirmed the breach conviction but reversed the attempted larceny conviction.
The Supreme Court granted certification to review both parties’ appeals, dismissed Adams’ certification as improvidently granted on the breach issue, and addressed the sufficiency of the evidence for attempted larceny.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Adams)	Held
Sufficiency of evidence for attempted sixth‑degree larceny (ownership element)	Surveillance, furtive conduct, abandonment of bag, flight, and the officers’ reported $979 valuation permit a reasonable inference the items belonged to Marshalls	No direct evidence identifying items as Marshalls’ property; valuation alone doesn’t establish ownership and officers may have guessed	Held: Evidence was sufficient; trial court could infer ownership from cumulative circumstantial evidence, including the specific valuation implying items were rung up (price‑tagged)
Use of flight to prove a crime occurred	Flight combined with other facts supports inference of criminal intent and that a crime occurred	Flight alone cannot establish that a crime occurred	Held: Flight is admissible and probative; ambiguities are for the factfinder to resolve; here flight plus other conduct strongly supports conviction

State v. Harris, 215 Conn. 189 (Conn. 1990) (corpus delicti rule requires corroborative evidence; corroboration may be circumstantial)
State v. Wolff, 237 Conn. 633 (Conn. 1996) (explains intent element for breach of the peace)
State v. Drupals, 306 Conn. 149 (Conn. 2012) (standard of review for sufficiency challenges)
State v. Morelli, 293 Conn. 147 (Conn. 2009) (instructs that appellate review asks whether evidence supports guilty verdict, not an innocence hypothesis)
State v. Buhl, 321 Conn. 688 (Conn. 2016) (circumstantial evidence may be cumulative and sufficient to prove guilt)