State v. Boutilier
133 Conn. App. 493
| Conn. App. Ct. | 2012Background
- Defendant Matthew Boutilier shot and killed Becky Ramos and wounded Yajaira Aponte during a domestic dispute in Hartford; Krantz was present but not harmed.
- Defendant was convicted of assault in the first degree under § 53a-59(a)(5) and criminal possession of a firearm under § 53a-217(a)(1).
- Defendant moved for temporary release from custody to view the crime scene with counsel and to attend a mock jury session; motions were denied.
- Defendant argued the denials violated his Sixth Amendment rights to counsel, to present a defense, and to confront witnesses; the court denied relief.
- Defendant also moved for the jury to view the crime scene; the court denied the request, relying on existing photographs and testimony.
- Prosecutorial impropriety claims were raised regarding closing and rebuttal arguments; the court denied mistrial requests and affirmed the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of temporary release was abusive discretion | Boutilier contends denial violated Sixth Amendment rights. | Boutilier argues the court should have allowed scene viewing and mock jury prep for defense. | Court held abuse of discretion standard; no constitutional right implicated; denial affirmed. |
| Whether denial of the jury view of the scene was error | Defense claims viewing necessary to understand self-defense claim. | Boutilier argues view would help the jury. | Court affirmed denial; photographs and testimony sufficed; no abuse of discretion. |
| Whether prosecutorial impropriety entitled defendant to mistrial | State asserts no improper conduct affected fairness; trial should not be overturned. | Prosecutor comment and tone prejudiced the defense and merits mistrial. | Court rejected grounds for mistrial; no reversible impropriety found. |
Key Cases Cited
- State v. Saucier, 283 Conn. 207 (2007) (abuse of discretion framework for trial court rulings)
- Doe v. Roe, 246 Conn. 652 (1998) (constitutional analysis of trial rulings; no direct right implicated)
- In re Lukas K., 120 Conn.App. 465 (2010) (analysis of whether a claim states a constitutional right)
- State v. Claudio C., 125 Conn.App. 588 (2010) (linking evidentiary claims to constitutional rights; first impression discussion)
- State v. Gibson, 302 Conn. 653 (2011) (prosecutorial impropriety standard and fair argument; demeanor considerations)
- State v. Singh, 259 Conn. 693 (2002) (two-step analysis of prosecutorial impropriety and unfair trial claim)
- State v. Ortiz, 280 Conn. 686 (2006) (abuse of discretion standard and fairness considerations)