State v. Campanaro
78 A.3d 267
Conn. App. Ct.2013Background
- The defendant, Dean Campanaro, was convicted after a jury trial of multiple sex offenses against a 14-year-old victim, E, who was longtime friend of his daughter H.
- The incidents began with a July 2008 camping trip to New York where E and H stayed with Campanaro’s family; E reportedly had sexual relations with Campanaro during a late-night encounter in a secluded area.
- After the vacation, E and Campanaro communicated frequently via text, phone, and email, including sexually explicit messages and photographs; E’s mother became concerned and sometimes confiscated her phone.
- On August 8, 2008, Campanaro allegedly spiked E’s drinks with vodka mixed with fruit punch, and they engaged in sexual relations; E’s mother later found her daughter intoxicated at Campanaro’s residence.
- DNA testing of E’s clothing and the defendant’s DNA was obtained; defense sought a continuance under § 54-86k(c) after the state disclosed DNA results shortly before trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Continuance denial under DNA disclosure | State contends standard 21-day period suffices; no abuse | Campa-naro sought 60 days to prepare defense | Court did not abuse discretion; acquiesced to 27-day continuance |
| In camera review of confidential records | Records not required to be reviewed; no impairment shown | Requests in camera review to impeach and present defense | Trial court did not abuse discretion; no sufficient showing for in camera review |
| Sixth Amendment right to counsel and prosecutor's access to defense strategy | No deliberate disclosure or prejudice to defense beyond trial | Prosecutor obtained and disclosed defense strategy via spouse’s document | Golding not satisfied; claim unpreserved; court declines to review |
Key Cases Cited
- State v. Golding, 213 Conn. 233 (Conn. 1989) (establishes framework for reviewing unpreserved constitutional errors)
- State v. Lenarz, 301 Conn. 417 (Conn. 2011) (limits on privilege-based claims when third-party disclosure occurs)
- State v. Slimskey, 257 Conn. 842 (Conn. 2001) (cross-examination rights do not compel pretrial disclosure of all potentially useful information)
- State v. McClelland, 113 Conn. App. 142 (Conn. App. 2009) (abuse of discretion standard for confidential-records review)
- State v. Victor C., 145 Conn. App. 54 (Conn. App. 2013) (continuance decision reviewable for abuse of discretion)