State v. Elson, 9 A.3d 731

Elson was convicted by jury of first‑degree assault and unlawful restraint; a part B information added a charge of committing these offenses while on pretrial release, and he was sentenced to 25 years with 20 to serve and 5 years of probation, on count consolidation.
The September 3, 2004 incident at Western Connecticut State University Danbury campus involved Elson approaching a female student with a knife, inflicting multiple injuries, and fleeing the scene; he later gave voluntary statements admitting intoxication and describing a hazy sequence of events.
Elson was released on bail for unrelated felony charges when the assaults occurred, which the court treated as an aggravating factor at sentencing.
At sentencing, the court commented on the defendant’s apology, questioned its sincerity, and stated views about the victim, the defendant’s intoxication history, and his dangerousness; it also referenced the defendant’s failure to plead and his pretrial release violations as aggravating factors.
On appeal, Elson challenged the sentencing remarks as unpreserved constitutional claims, arguing due process was violated by consideration of (a) the decision to stand trial and (b) the knife exhibit; the defense also invoked Golding and supervisory authority procedures but the panel ultimately affirmed the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentencing remarks violated due process by penalizing the defendant for standing trial	Elson	Elson	No due‑process violation found; record ambiguous and court did not clearly augment sentence for trial decision.
Whether the court impermissibly relied on the knife exhibit at sentencing	Elson	Elson	No due‑process violation found; knife was admitted at trial and discussed as evidence, not an improper sentencing factor.
Whether Golding review was available and properly requested for an unpreserved claim	Elson	Elson	Golding review not satisfied because no affirmative request in the main brief; supervisory review declined; judgment affirmed.
Whether the court's invocation of supervisory authority to review the unpreserved claim was appropriate	Elson	Elson	Not warranted; supervisory review declined; remand not ordered.

State v. Golding, 213 Conn. 233 (Conn. 1989) (establishes four‑part test for unpreserved constitutional claims)
State v. Evans, 165 Conn. 61 (Conn. 1973) (exceptional circumstances for unpreserved claims; fundamental rights)
State v. Ramos, 261 Conn. 156 (Conn. 2002) (recognizes supervisory review but emphasizes record adequacy and preservation)
State v. Kelly, 256 Conn. 23 (Conn. 2001) (totality of circumstances test for sentencing based on right to trial)
State v. Wright, 114 Conn.App. 448 (Conn. 2009) (discussed affirmative request for Golding review in Wright (reconsidered))