323 Conn. 654
Conn.2016Background
- Defendant Adam Benedict, a substitute teacher, was tried twice for sexual assault; first trial ended in mistrial on assault counts; retrial resulted in conviction on one count.
- During second trial voir dire, venireperson J.J., a Southbury police officer, stated his “boss” was a state police sergeant and that he worked “under the state police,” but did not personally know the troopers who investigated the case.
- Defendant exhausted peremptory challenges and moved to strike J.J. for cause, arguing implied bias from J.J.’s employment relationship with the investigating state police.
- Trial court denied the challenge, finding no per se rule disqualifying police officers and that J.J.’s answers showed he could be fair and impartial and did not know the state troopers involved.
- On appeal, Appellate Court upheld denial for cause for lack of proof of a master-servant relationship with the investigating troopers; Supreme Court affirmed, holding defendant failed to prove the requisite close relationship.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a juror employed in law enforcement must be removed for cause when he has employment ties to the agency that investigated the case | State: no per se disqualification; removal requires proof of close relationship likely to cause bias | Benedict: J.J.’s status as Southbury officer who reports to a state trooper who is in the investigating agency creates a principal challenge requiring removal | Court: employment alone not disqualifying; defendant failed to prove close/master-servant relationship or personal ties to investigating troopers, so no removal required |
| Whether principal challenges extend to relationships with witnesses or only parties | State: principal challenge limited to relationships with a party; investigating agency isn’t a party | Benedict: an investigating agency’s close ties to juror should suffice for principal challenge | Court: principal challenges can extend to close relationships with witnesses/ investigating agency, but must be proven in voir dire |
| Whether the trial court abused discretion in denying for-cause challenge given J.J.’s answers | State: J.J. said he could be impartial and did not know trial troopers | Benedict: speculative future interactions and chain-of-command create implied bias | Court: trial court reasonably relied on juror’s assurances and lack of demonstrated close ties; no abuse of discretion |
| Standard of review and burden on party raising principal challenge | N/A | Benedict: must show prohibited relationship during voir dire | Court: party asserting principal challenge must prove factual basis at voir dire; disqualification is conclusively presumed only if shown |
Key Cases Cited
- Morgan v. St. Francis Hospital & Medical Center, 216 Conn. 621 (absolute bias presumption follows from certain close relationships)
- State v. Esposito, 223 Conn. 299 (distinguishing principal challenge and tolerance for policing juror employment alone)
- McCarten v. Connecticut Co., 103 Conn. 537 (common-law bases for principal challenge described)
- State v. Clark, 164 Conn. 224 (police employment alone is not per se disqualifying)
- Dennis v. United States, 339 U.S. 162 (discussion on class disqualification and government employment)
- Mikus v. United States, 433 F.2d 719 (Second Circuit: police membership not presumptively disqualifying)
- Tate v. People, 125 Colo. 527 (juror reporting to a prosecuting witness supports removal)