State v. Crenshaw, 313 Conn. 69

Crenshaw was convicted after a joint trial of Hartford assault (third degree), Hartford second-degree kidnapping, and Enfield murder with Enfield second-degree kidnapping.
Two informations were consolidated for trial: Hartford charges (kidnapping first degree and assault) and Enfield charges (murder and kidnapping second degree).
The victim, Ashley Peoples, was abducted on August 7, 2008, at a salon, then transported in Crenshaw’s car, where she was assaulted and later died from strangulation and blunt-force injuries.
Following abduction, Crenshaw allegedly dragged, punched, and restrained the victim over approximately 12–20 hours across locations, including the salon, Crenshaw’s car, 777 Maple Avenue, and the apartment where her body was found.
The State sought to prove two separate kidnappings by showing two instances of abduction and lack of liberation, while Crenshaw argued kidnapping was a continuous, single act.
The trial court granted consolidation, and the jury found Crenshaw guilty of Hartford assault and second-degree kidnapping, and murder and second-degree kidnapping in Enfield; the Enfield second-degree kidnapping count was later appealed and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consolidation was proper	Cross-admissibility of evidence supports consolidation.	Joinder risks substantial prejudice and lack of discrete scenarios.	Consolidation proper; evidence would be cross admissible and prejudice cured by instructions.
Sufficiency of second-degree kidnapping convictions	Two separate kidnappings occurred—the victim was abducted twice and restrained without consent.	Kidnapping was a continuous act; no two separable abductions occurred.	Only one kidnapping event proven; Enfield second-degree kidnapping acquitted; Hartford second-degree kidnapping upheld.

State v. LaFleur, 307 Conn. 115 (2012) (joinder discretion and cross admissibility principle)
State v. Pollitt, 205 Conn. 61 (1987) (cross admissibility governs joinder analysis)
State v. Gomez, 225 Conn. 347 (1993) (kidnapping is a continuing crime)
State v. Freeney, 228 Conn. 582 (1994) (double jeopardy concerns for continuous kidnapping)
State v. Boscarino, 204 Conn. 714 (1987) (Boscarino factors for prejudice from non-cross-admissible evidence)
State v. Salamon, 287 Conn. 509 (2008) (evidence of intent and motive in kidnapping context)
State v. Ali, 233 Conn. 403 (1995) (context for completing the story and admissibility of conduct evidence)