State v. Chankar, 162 A.3d 756

Background

Defendant Marwan Chankar was convicted by a jury of first‑degree arson and first‑degree criminal mischief for a July 9, 2011 fire at a multi‑family house where he had been staying; acquitted of attempted murder. Sentenced to 17 years plus six years special parole.
Key evidence: (1) testimony from Laura Wallace that Chankar told her he started the fire and described large flames; (2) witnesses who saw the fire and photos of its progression; (3) firefighters/investigators who found burn patterns consistent with an intentionally set fire; (4) an accelerant‑detection canine alerted and laboratory testing found a medium boiling range petroleum distillate in a kitchen sample.
On July 26, 2011 two plain‑clothes officers approached Chankar at a methadone clinic, asked to speak, and interviewed him at the back of a cemetery for ~30–45 minutes. Officers neither handcuffed nor drew weapons, told him he was free to leave, and returned his backpack when the interview ended. No Miranda warnings were given.
Defense moved to suppress the July 26 statements as the product of custodial interrogation; motion denied. Trial followed and Chankar appealed raising Miranda/custody, sufficiency of evidence as to arson, and prosecutorial improprieties in closing argument.
The trial court’s factual findings (from the suppression hearing) were credited; on appeal the Connecticut Appellate Court affirmed in all respects.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Chankar)	Held
Whether July 26 interview was custodial — Miranda required	Interview was noncustodial: Chankar voluntarily met officers, was told he was free to leave, unrestrained, short interview	Officers effectively restrained him (secluded location, removal of backpack, inability to leave) so Miranda was required	Not custodial; Miranda not required (court credited officers; Mangual factors applied)
Sufficiency of evidence for first‑degree arson	Cumulative circumstantial evidence (Wallace’s admission testimony, motive, access to accelerant, canine and lab results, timeline) supports conviction	Evidence was inadequate; Wallace unreliable; physical evidence inconsistent with her account	Sufficient — jury reasonably could find guilt beyond reasonable doubt based on cumulative evidence
Prosecutorial impropriety — statements about area/origin of fire and dog alerts	Prosecutor’s comments were fair inferences from evidence and reasonable argument; any isolated misstatements were harmless	Prosecutor misstated facts (said dog alerted at curtains, said state didn’t know origin) and gave improper personal opinions, prejudicing fairness	No reversible impropriety: comments were permissible argument or isolated misstatements considered harmless in context; trial court’s standard jury charge sufficed
Whether cumulative errors deprived defendant of a fair trial	—	Cumulative effect of Miranda, evidentiary and closing argument errors warranted reversal	No cumulative error; convictions affirmed

Key Cases Cited

Miranda v. Arizona, 384 U.S. 436 (establishes Miranda warnings requirement for custodial interrogation)
State v. Mangual, 311 Conn. 182 (framework/factors for determining custody for Miranda)
State v. Arias, 322 Conn. 170 (discusses Mangual factors and custody analysis)
State v. Crespo, 317 Conn. 1 (standard for reviewing sufficiency of evidence)
State v. O'Brien-Veader, 318 Conn. 514 (prosecutorial impropriety standard and review of prejudice)