State v. Douglas
11 A.3d 699
Conn. App. Ct.2011Background
- Douglas and his brother aligned with the New Haven boys against the Twiss Street gang over disputes at Maloney High School in Meriden.
- A January 18, 2008 statement by Robert Rios described Douglas and associates with a gun and plans to shoot at a crowd.
- Approximately four months later, on April 30, 2008, Adorno testified three individuals matching jacket descriptions shot on Liberty Street.
- Police found jackets matching the descriptions at Douglas's home, which Adorno later identified as worn by the shooters.
- Gunshot residue testing showed lead on Douglas’s jacket and his left-handedness; shell casings at the scene matched a .38 caliber weapon.
- Douglas was tried January 29–30, 2009, convicted on all counts, and sentenced to eight years with eight years’ special parole.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of conspiracy evidence | State | Douglas | Sufficient evidence supports conspiracy convictions |
| Sufficiency of reckless endangerment evidence | State | Douglas | Sufficient evidence shows extreme indifference or planned shootout |
| Carrying a pistol without a permit | State | Douglas | Sufficient evidence the jacket contained gunshot residue and firearm presence outside dwelling |
| Admission of Rios prior uncharged misconduct | State | Douglas | Evidence admissible with limiting instructions; two portions deemed irrelevant but not outcome-determinative |
Key Cases Cited
- State v. Millan, 290 Conn. 816 (2009) (conspiracy requires agreement and overt act; intent inferred from conduct)
- State v. Wells, 100 Conn.App. 337 (2007) (an appellate sufficiency review relies on view most favorable to prosecution)
- State v. Padua, 273 Conn. 138 (2005) (conspiracy requires intent to commit the object offense)
- State v. Hanks, 39 Conn.App. 333 (1995) (intent is state of mind proven by circumstantial evidence)
- State v. Estrada, 28 Conn.App. 416 (1992) (reversed conspiracy where inferential chain was weak)
- State v. Collins, 111 Conn.App. 730 (2008) (admissibility of prior shootings depends on probative value vs. unfair prejudice)
- State v. Santos, 104 Conn.App. 599 (2007) (limitations on evaluating competing inferences in appellate review)