State v. Antonaras, 137 Conn. App. 703

Defendant Constantinos Antonaras was convicted after a jury trial of five counts of first-degree sexual assault, nine counts of second-degree sexual assault, and fourteen counts of risk of injury to a child.
Evidence included charged conduct involving D, a 9–16-year-old victim, and uncharged misconduct with two other minors, C and R.
The State sought to admit C and R’s testimony under a liberal common-scheme/plan standard, later refined to a propensity standard for sex crimes by DeJesus.
The court admitted C and R’s testimony as uncharged misconduct under the common-scheme/plan framework and gave limiting instructions.
Defendant challenged the admission of C and R’s testimony, the jury instruction re common plan, and a claimed conflict of interest involving defense counsel and the Hartford police; all issues were resolved with the judgment affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of uncharged misconduct (C and R)	State contends evidence was admissible under DeJesus liberal standard.	Antonaras argues the evidence was too remote and dissimilar and should be prejudicial.	Agreed probative value outweighed prejudice; evidence admissible under improper standard but harmless under DeJesus framework.
Jury instruction on uncharged misconduct as common scheme	State argues instruction correctly limited to common plan; supports admission.	Instruction improperly limited propensity vs. common plan.	Error but harmless; instructing on common scheme was harmless under DeJesus/Johnson rationale.
Conflict of interest in defense counsel	N/A (defense argued conflict); court reviewed unpreserved claim.	Conflict of interest claim unpreserved; could affect cross-examination.	Golding review not triggered; claim unreviewable for lack of preservation.
Retroactivity of DeJesus ruling	DeJesus applies to cases pending on appeal.	Could be prospective only.	DeJesus applied retroactively to pending cases; error not reversible for those reasons.

State v. DeJesus, 288 Conn. 418 (2008) (established propensity exception for sex crimes with cautionary instructions)
State v. Gupta, 297 Conn. 211 (2010) (similarity/severity factors in uncharged misconduct analysis)
State v. Ellis, 270 Conn. 337 (2004) (frequency/severity as factors in similarity; location and relationship matter)
State v. Jacobson, 283 Conn. 618 (2007) (grooming/gift-giving beyond actual abuse can support similarity)
State v. Johnson, 289 Conn. 437 (2008) (harmless error with DeJesus framework; cross-reference to Johnson/DeJesus)