State v. Ames
157 A.3d 660
Conn. App. Ct.2017Background
- Defendant Mary J. Ames stabbed and killed bartender Christopher Hall at Doran’s Bar after an argument following a pool game; the fatal wound was a chest stab from a ~3.5" knife.
- Five people were present; several had been drinking heavily. The court found Ames and her son participated in an assault and that Ames wielded the knife.
- Charged with murder, felony murder, and attempt to commit first‑degree robbery; tried before a three‑judge court. The court convicted Ames of murder but acquitted on felony murder and attempted robbery.
- Ames claimed (1) self‑defense under § 53a‑19 and (2) affirmative defense of extreme emotional disturbance (EED) under § 53a‑54a(a); presented expert testimony diagnosing PTSD.
- Trial court rejected both defenses, found Ames was the initial aggressor, did not credit that the victim grabbed her throat (a key trigger alleged), and found circumstantial evidence supported specific intent to kill.
- Sentenced to 35 years plus 10 years special parole; appeal challenges EED ruling, rejection of self‑defense, finding of specific intent, and court interruptions during closing.
Issues
| Issue | State's Argument | Ames' Argument | Held |
|---|---|---|---|
| Whether Ames proved extreme emotional disturbance by a preponderance | State: Ames failed to prove the triggering fact (victim grabbed throat) and expert opinion relied on unproven facts | Ames: Expert and her testimony showed PTSD was triggered by victim’s contact, producing EED | Court: Affirmed — ample evidence supports rejecting EED because key subordinate fact (throat grab) was not credited and expert opinion relied on it |
| Whether self‑defense was disproved beyond a reasonable doubt | State: Evidence established Ames was initial aggressor who pursued, threatened, lunged and attacked victim | Ames: Claimed she was defending herself after the victim touched/grabbed her | Court: Affirmed — reasonable for fact‑finder to find Ames was initial aggressor and state met its burden to disprove self‑defense |
| Whether the state proved specific intent to kill beyond a reasonable doubt (despite intoxication) | State: Circumstantial evidence (vital‑area stab to heart, force, defensive wounds on victim, flight, concealment) supports intent despite intoxication | Ames: Intoxication and confusion negated capacity to form specific intent | Court: Affirmed — inferences from weapon use, wound location, flight/concealment supported specific intent; intoxication did not automatically negate intent |
| Whether trial court’s interruptions during closing deprived Ames of counsel and fair trial | State: Interruptions clarified issues and aided counsel; defense was not prevented from arguing its theories | Ames: Court’s questioning constituted premature deliberation and hindered counsel’s presentation | Court: Affirmed — interruptions were not prejudicial; defense had opportunity to argue and court’s questions clarified issues rather than precluded argument |
Key Cases Cited
- State v. Forrest, 216 Conn. 139 (1990) (defines two elements of EED defense)
- State v. Crespo, 246 Conn. 665 (1998) (enumerates subsidiary factual showings required for EED)
- State v. Blades, 225 Conn. 609 (1993) (presence/absence of EED is a factual determination for the trier)
- State v. Chace, 199 Conn. 102 (1986) (intent to kill may be inferred from weapon, manner, wounds, and surrounding events)
- State v. Jones, 320 Conn. 22 (2015) (defines initial aggressor)
- State v. D’Antuono, 186 Conn. 414 (1982) (standard for construing evidence in favor of sustaining fact‑finder’s conclusions)