State v. Bonilla, 317 Conn. 758

Bonilla, along with his brothers Bermudez and Santiago, planned to rob Morales after learning Morales would likely have money; Bonilla acted as lookout while Bermudez approached Morales and shot him, they fled with a bank bag, and Santiago drove the getaway car.
After the murder, the brothers travelled to Santiago’s home; Algarin-Santiago saw them with cash, and Bermudez admitted the shooting and the defendants threatened her and her mother if she spoke.
The brothers burned clothes, cleaned the getaway car, and disposed of the gun, then devised an alibi; Morales’s murder remained unsolved for over a decade.
In 2010, Santiago and Algarin-Santiago provided information to police; Bonilla was arrested and gave a detailed statement corroborating the events, leading to a two-count information charging murder as an accessory and felony murder.
Trial occurred with no defense evidence; the jury convicted Bonilla of murder as an accessory and felony murder; the trial court merged the convictions and imposed a single sixty-year sentence.
Bonilla appeals asserting insufficient evidence to support accessory liability and that the court failed to sua sponte instruct on duress.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for murder as an accessory	Bonilla lacked intent to kill Morales	Bonilla did share the killer’s intent	Evidence supported shared intent and guilt
Duress instruction sua sponte	Duress evidence required instruction	No sua sponte obligation to instruct on duress	No sua sponte instruction required; not preserved or entitled to Golding review

State v. Bennett, 307 Conn. 758 (2013) (shared intent to kill may be inferred; motive strengthens case)
State v. Crespo, 317 Conn. 1 (2015) (circumstantial evidence can prove guilt beyond reasonable doubt)
State v. Rodriguez, 180 Conn. 382 (1980) (intent proved by circumstantial evidence and patterns of conduct)
State v. Sivri, 231 Conn. 115 (1994) (destruction of evidence admissible to show consciousness of guilt)
State v. Ebron, 292 Conn. 656 (2009) (trial court not obligated to sua sponte instruct on defenses not requested)
State v. Santiago, 305 Conn. 101 (2012) (defendant bears burden to raise defenses; due process considerations)
State v. Helmedach, 306 Conn. 61 (2012) (duress instruction discussed but distinguishable facts; not controlling here)
State v. Heinemann, 282 Conn. 281 (2007) (duress instruction considerations in different context; not controlling here)
State v. Kitchens, 299 Conn. 447 (2011) (Kitchens governs preservation and appellate review of trial errors)
State v. Pulaski, 71 Conn. App. 497 (2002) (line of sufficiency cases later refined; not dispositive here)