State v. Crespo, 317 Conn. 1

Victor Crespo was arrested Jan. 18, 2010 and later gave a written statement to Ortiz the next day.
Pistols were found in Crespo’s van after Stern recovered a black garbage bag containing a loaded Uzi-type pistol.
Crespo was charged with carrying a pistol without a permit, having a weapon in a motor vehicle without a permit, and possession of an assault weapon.
Crespo moved to suppress the written statement under General Statutes § 54-1c, arguing he had not been presented to the first court session in time.
The trial court admitted the statement; the Appellate Court affirmed; the Supreme Court granted review on two issues.
The court held that § 54-1c does not bar admissibility when the statement is obtained before presentation but the delay does not stem from interrogation to obtain a confession, and that the evidence was sufficient to prove carrying a pistol under § 29-35(a).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 54-1c bars the statement obtained before presentation	Crespo contends the statute applies to any statement not timely presented.	State contends § 54-1c applies only to statements obtained before or after delay affecting presentment.	Statute not bar; timing interpretation favors admissibility.
Whether the evidence proves carrying a pistol under § 29-35(a)	Evidence shows possession in the van; no proof the weapon was on Crespo’s person.	Carrying requires on-person control; there was no direct testimony of on-person possession.	Evidence sufficient to support guilty verdict; jury could infer carrying.

Mallory v. United States, 354 U.S. 449 (U.S. 1957) (prompt presentment goals; third degree interrogation concerns)
McNabb v. United States, 318 U.S. 332 (U.S. 1943) (premature interrogation and delay concerns)
Corley v. United States, 556 U.S. 303 (U.S. 2009) (delay for interrogation is the epitome of unnecessary delay)
Culombe v. Connecticut, 367 U.S. 568 (U.S. 1961) (confessions after arrest and before delay scrutiny)
United States v. Mitchell, 322 U.S. 65 (U.S. 1944) (confession follow-up and unlawful detention distinctions)
State v. Vollhardt, 157 Conn. 25 (Conn. 1968) (clarity of 54-1c language and arraignment timing)
State v. Hopes, 26 Conn. App. 367 (Conn. App. 1992) (dominion and control in carrying a pistol)
State v. Blackman, 246 Conn. 547 (Conn. 1998) (evidence must be the product of legal rights; exclusion rules)
State v. Calabrese, 279 Conn. 393 (Conn. 2006) (circumstantial evidence and reasonable jury inferences)