State v. Brantley
138 A.3d 347
| Conn. App. Ct. | 2016Background
- Defendant Aaron Brantley, a New Haven firefighter, was tried to the court and convicted under Conn. Gen. Stat. § 53a-149 for bribery of a witness based on offers to two coworkers (Corey Bellamy and Faustino Lopez) of 2–3% of any proceeds from Brantley’s civil claims in exchange for favorable testimony.
- Bellamy gave a police statement that the defendant offered a percentage; at trial Bellamy recanted but the court found his police statement credible.
- Lopez told police the defendant asked him to say Egan had harassed Brantley and offered 2–3% of proceeds; Lopez declined and later reported the call to a supervisor.
- The trial court found Brantley offered benefits to both witnesses and that he had the specific intent to influence Lopez’s testimony; conviction was based on the court’s credibility findings.
- Brantley moved for a new trial and judgment of acquittal; both were denied. He appealed arguing (1) the state’s sufficiency-of-the-evidence standard undermines due process, and (2) insufficient evidence that he intended to influence Lopez or actually offered Lopez a benefit.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Brantley) | Held |
|---|---|---|---|
| Adequacy of Connecticut sufficiency-of-evidence standard | Existing standard (view evidence in light most favorable to prosecution; ask whether any rational trier of fact could find guilt beyond a reasonable doubt) protects due process | Standard permits affirmance on "some evidence," diluting proof-beyond-a-reasonable-doubt requirement | Court rejected challenge; bound by Supreme Court precedent and held the current standard is consistent with Jackson v. Virginia and protects Winship due process rights |
| Sufficiency of evidence of intent to influence Lopez | Lopez’s statement that Brantley asked him to alter testimony and offered payment supported an inference Brantley intended to influence testimony | Argued there was no evidence what Lopez would have otherwise said or how requested testimony differed; thus intent not proved | Court held Lopez’s credible statement and surrounding circumstances permitted a reasonable inference Brantley sought to induce Lopez to testify more favorably—intent proven beyond reasonable doubt |
| Sufficiency of evidence that a benefit was offered to Lopez | Testimony from Lopez and corroborating phone records and related witness statements established an actual offer of 2–3% | Defendant presented alibi/testimony (Hewitt) and claimed the offer was a joke, arguing the state failed to prove he was present or actually made the offer | Court credited Lopez over defendant; timing need not be exact; evidence was sufficient to find an offer of a benefit |
Key Cases Cited
- State v. Drupals, 306 Conn. 149 (2012) (articulates Connecticut standard for sufficiency review: view evidence in light most favorable to prosecution and ask whether any rational trier of fact could find guilt beyond a reasonable doubt)
- Jackson v. Virginia, 443 U.S. 307 (1979) (federal standard for sufficiency review after Winship: asks whether record evidence could reasonably support a finding of guilt beyond a reasonable doubt)
- State v. Ventola, 122 Conn. 635 (1937) (holding bribery statute covers offers intended to alter, sway, or affect testimony, not only to induce false testimony)
- State v. Davis, 160 Conn. App. 251 (2015) (elements required for conviction under § 53a-149)
- State v. Morelli, 293 Conn. 147 (2009) (deference to factfinder on resolution of conflicting evidence and credibility)