153 Conn.App. 419
Conn. App. Ct.2014Background
- Defendant Sheila Davalloo had an obsessive love triangle with coworker Nelson Sessler and victim Anna Lisa Raymundo at Purdue Pharma in Stamford.
- She lied to her husband Paul Christos about a mentally ill brother to conceal affairs and to facilitate meetings with Sessler at a Pleasantville, New York condominium.
- Raymundo was murdered in 2002; later Davalloo stabbed her husband Christos in 2003 in New York, leading to a separate attempted-murder charge.
- DNA found on a sink handle from the victim’s apartment contained genetic material from both Davalloo and Raymundo, with testimony regarding DNA longevity questions.
- Davalloo was convicted of murder under Conn. Gen. Stat. § 53a-54a after a jury trial and appealed on marital privilege, uncharged misconduct evidence, and waiver of counsel.
- The trial included extensive testimony about Davalloo’s schemes to manipulate others to remove rivals and to further her relationship with Sessler.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether marital communications privilege excluded the evidence | Davalloo, Davalloo argues communications were privileged | State contends communications not induced by affection in marriage | Privilege not applicable; communications not 'induced by affection' |
| Admissibility of uncharged misconduct to prove motive/identity | State argues uncharged acts show motive/plan | Evidence is propensity and prejudicial, lacks proper similarity | Court properly admitted as relevant under two-part test with limiting instructions |
| Validity of Davalloo’s waiver of counsel | Golding review applies; claim preserved | Canvas flawed; ineffective waiver | canvass adequate; waiver knowingly, intelligently made |
Key Cases Cited
- State v. Mark R., 300 Conn. 590 (2011) (testing standards for privilege questions; clearly erroneous findings)
- State v. Christian, 267 Conn. 710 (2004) (common-law marital privilege; confidential communications)
- State v. Adams, 308 Conn. 263 (2013) (statutory interpretation of privilege)
- State v. Collins, 299 Conn. 567 (2011) (Golding framework and canvass adequacy)
- State v. Randolph, 284 Conn. 328 (2007) (evidence of uncharged misconduct; two-part admissibility test)