State v. Baptiste, 23 A.3d 1233

defendant Baptiste was convicted after a jury trial of assault on a peace officer (53a-167c(a)) and two counts of interfering with an officer (53a-167a(a));
he challenged the trial court’s jury instructions as violating his right to a fair trial/defense but did not object at trial;
the Appellate Court held he waived the claim under Kitchens because counsel allegedly had a meaningful opportunity to review the proposed instructions;
this Court granted certification to decide whether waiver applies when the defense did not receive an advance copy of the proposed instructions and the charging conference was off the record;
the majority held Baptiste did not waive, remanding for merits review under Golding;
the opinion endorses providing advance copies of charges when feasible and notes off-the-record conferences should be carefully documented, without overruling Kitchens

Issue	Plaintiff's Argument	Defendant's Argument	Held
Waiver of instructional error under Kitchens when no advance copy was provided	Baptiste; waiver not shown	Baptiste; no meaningful opportunity to review	Not waived; Golding review available

State v. Kitchens, 299 Conn. 447 (Conn. 2011) (waiver of instructional challenge if counsel reviews proposed instructions)
State v. Collins, 299 Conn. 567 (Conn. 2011) (no advance copy; uncertain review of written charge)
State v. Brown, 299 Conn. 640 (Conn. 2011) (record insufficient to determine waiver of instruction)
State v. Golding, 213 Conn. 233 (Conn. 1989) (unpreserved constitutional error review standard)
State v. Thomas W., 301 Conn. 724 (Conn. 2011) (plenary review standard for waivers)