State v. Crafter, 198 Conn.App. 732

Laura Crafter was convicted by a jury of first‑degree assault with a dangerous instrument after a November 20, 2015 confrontation that left the victim with multiple lacerations (face, thumb, back) requiring sutures and causing permanent scarring.
The altercation arose while two men (Michael and Demetrius Reed) were engaged in a violent fistfight; Crafter approached the scene carrying a ten‑inch kitchen knife.
The victim attempted to intervene and, according to her testimony, Crafter poked her in the forehead with the knife; a struggle for the knife ensued and the victim sustained the injuries.
Crafter testified she was unarmed, denied using a knife, and claimed she was trying to defend Michael; she also admitted to making false statements to police after the incident.
At trial the court denied Crafter’s motion for judgment of acquittal; the jury convicted on one count (assault in the first degree). Crafter appealed, arguing insufficient evidence of specific intent, that the state failed to disprove self‑defense, and that the court committed plain error by not giving a defense‑of‑others instruction sua sponte.

Issue	State's Argument	Crafter's Argument	Held
Sufficiency of evidence to prove specific intent to cause serious physical injury	Evidence (weapon type/use, severity/location of wounds, preincident spat/punch, postincident conduct) permits reasonable inference of intent	Victim’s inability to pinpoint how wounds were inflicted and chaotic struggle showed no specific intent; could be accidental	Affirmed — viewing evidence favorably to verdict, jury could infer intent from use of a large knife, multiple/scarring wounds, prior spat/punch, and consciousness of guilt
Whether state disproved self‑defense beyond a reasonable doubt	Self‑defense claim is governed by binding precedent; the state relied on evidence undermining the claim	Crafter argued she acted to defend Michael and did not intend deadly force	Court declined to resolve merits here because issue is controlled by State v. Singleton; Crafter preserved it for appeal but it did not change outcome
Whether trial court committed plain error by failing to instruct sua sponte on defense of others	Trial courts are not required to give defense instructions sua sponte except in narrow statutory situations; no obligation here	Crafter argued plain error because she sought to defend Michael and the jury should have been instructed on defense of others	Affirmed — no sua sponte duty to instruct on defense‑of‑others; Ortiz is limited to statutory defenses expressly in a statute and does not establish a broad plain‑error rule

State v. Allan, 311 Conn. 1 (Conn. 2014) (standard for reviewing sufficiency of the evidence)
State v. Carpenter, 214 Conn. 77 (Conn. 1990) (insufficient evidence to infer specific intent where accidental injury plausible)
State v. Williams, 187 Conn. App. 333 (Conn. App. 2019) (distinguishing facts where intent to harm not shown)
State v. Pommer, 110 Conn. App. 608 (Conn. App. 2008) (permissible inference that defendant intended natural consequences of voluntary conduct)
State v. Wells, 100 Conn. App. 337 (Conn. App. 2007) (intent may be inferred from type of weapon and manner of its use)
State v. Bunker, 27 Conn. App. 322 (Conn. App. 1992) (an instantaneous act can support first‑degree assault intent)
State v. Ebron, 292 Conn. 656 (Conn. 2009) (trial courts have no duty to charge defenses sua sponte when not requested)
State v. Ortiz, 71 Conn. App. 865 (Conn. App. 2002) (limited to statutory defenses expressly in the statute; court clarifies its scope)
State v. Bonilla, 317 Conn. 758 (Conn. 2015) (court will not place on trial judge the duty to discern unrequested defenses)
State v. Bryan, 307 Conn. 823 (Conn. 2013) (describes structure and limits of defense‑of‑others justification)
State v. Singleton, 292 Conn. 734 (Conn. 2009) (governs self‑defense issues and controls related claims)