State v. Campbell, 300 Conn. 368

Campbell was charged with first-degree assault and carrying a dangerous weapon (switchblade) in a college dorm hallway; jury found not guilty of assault and guilty of carrying a dangerous weapon; Appellate Court affirmed; Supreme Court granted limited certification on whether the Appellate Court properly relied on State v. Sealy to conclude common dorm corridors are not abode; Court also considered whether §§ 53-206(b)(3)(D)-(E) provide an implicit abode exception for weapons other than long knives and, if so, whether that affects instruction.
The legislature revised § 53-206 in 1999, separating prohibitions from exceptions and restricting the abode-related exceptions (D) and (E) to long knives; § 53-206(b)(3) now lists only D and E related to long knives.
The Court held that the D and E abode exceptions apply only to long knives and do not extend to switchblades or other weapons; thus Campbell was not entitled to a jury instruction based on an abode exception for non-long knives.
Even though Sealy recognized an implicit abode exception for long knives, the 1999 amendments extinguished a general abode exception for all dangerous weapons; the Court affirmed the Appellate Court on the alternate ground and did not reach whether the dorm hallway constitutes an abode.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Do § 53-206(b)(3)(D)-(E) authorize an abode exception for weapons other than long knives?	Campbell; abodes exist for long knives and possibly other weapons under Sealy.	State; D and E apply only to long knives.	No; D and E apply only to long knives.
Is the hallway dormitory an abode under § 53-206 for purposes of the statute?	Campbell; hallway constitutes abode under Sealy.	State; not an abode; exceptions narrow by statute.	Not necessary to decide; affirmed on alternate ground.

State v. Sealy, 208 Conn. 689 (1988) (implicit abode exception; privacy in dwelling; long knives context)
State v. Campbell, 116 Conn.App. 440 (2009) (appellate court decision on abode and § 53-206; affirmed)
State v. Canady, 297 Conn. 322 (2010) (court presumes legislature aware of statutory interpretation)
State v. Golding, 213 Conn. 233 (1989) (test for constitutional error not raised at trial)