State v. Dillard, 31 A.3d 880

Dillard was convicted after a jury trial of manslaughter in the first degree, robbery in the first degree, attempt to commit robbery in the first degree, and threatening in the second degree.
Victim Patricia Austin lived with the defendant; he resided there for about six months and pursued a romantic relationship with her.
On April 18, 2007, the defendant stabbed the victim during a forcible confrontation, causing fatal injuries.
After the stabbing, the defendant fled in a stolen green Subaru Impreza and was later arrested in New Haven; a bloodstained sweatshirt was found in the car.
The State charged him with murder and related offenses; he pled Alford to a protective order violation, which the state later replaced; trial resulted in convictions on the remaining counts and a 36-year sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Conflict-of-interest duty regarding counsel	Dillard; court should have inquired after assault by counsel	Court had no duty to inquire given defense counsel’s assurances and defendant’s affirmations	No duty to inquire; no conflict established based on facts and representations
Admissibility of prior act evidence	Evidence of April 7 and 15, 2007, shows intent and motive	Prior acts were inflammatory and prejudicial, irrelevant to the charged crimes	Evidence admissible under 4-5(b) for intent/motive; not unduly prejudicial with limiting instructions
Joinder/severance of charges	Joinder prejudices defendant by combining distinct charges	Joinder was proper as evidence of one incident would be cross-admissible at separate trials	No abuse of discretion; severance denied; joinder proper under governing statutes and caselaw

State v. Parrott, 262 Conn. 276 (2003) (discusses reviewing ineffectiveness claims on direct appeal)
State v. Cator, 256 Conn. 785 (2001) (conflict-of-interest inquiry duties when trial court knows or should know of conflict)
State v. Crespo, 246 Conn. 665 (1998) (ethics obligation of attorney to disclose conflicts; court may rely on counsel’s representations)
State v. Barnes, 99 Conn.App. 203 (2007) (no duty to inquire where defendant affirmatively accepts counsel after alleged conflict)
State v. Beavers, 290 Conn. 386 (2009) (admissibility of other-crimes evidence for intent/motive; balancing test)
State v. Pereira, 113 Conn.App. 705 (2009) (misconduct evidence admissible for intent; not required to prove similarity for intent)
State v. James G., 268 Conn. 382 (2004) (limiting instructions on prior misconduct evidence reduce prejudice)
State v. Epps, 105 Conn.App. 84 (2007) (prior uncharged misconduct not unduly prejudicial when not as egregious)
State v. Gupta, 297 Conn. 211 (2010) (joinder presumption in favor of consolidation; severance requires substantial injustice)