195 Conn.App. 113
Conn. App. Ct.2019Background
- Defendant Maurice Francis and the victim cohabited; the victim had a history of cut and bruising after beginning to date the defendant.
- On Nov. 1, 2008, a neighbor observed the defendant drag an unresponsive woman from their building, place her in his silver 1998 Volvo, and drive away; the neighbor recorded the license plate.
- The defendant left the victim in the 1998 Volvo at Sparks Motor Sales for roughly 6–7 hours, later transferred her into a 1999 Volvo, returned to the apartment, placed the victim in the bathtub, and called 911 late that night claiming he had just found her.
- Autopsy revealed multiple fresh incised wounds and blunt-force bruises; cause of death was blood loss. Blood matching the victim was found in the apartment and on the passenger seat of the 1998 Volvo; a clump of the victim’s braided hair was found outside the building.
- The defendant lied to 911 and police about his whereabouts and timing, did not summon medical aid when the victim was injured, and the prosecution presented consciousness-of-guilt evidence (dragging body, concealment in vehicles, delayed 911 call).
- After the state rested the defendant moved for a judgment of acquittal (denied), rested without presenting evidence, a jury convicted him of murder, and he appealed raising insufficiency of evidence and a request to change the appellate sufficiency standard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency to prove defendant caused death and had specific intent to kill | Cumulative circumstantial evidence (multiple incised wounds, blood loss diagnosis, blood in car/apartment, victim could not self-inflict all wounds, defendant's post-event conduct and lies) supports inference he wounded victim with a sharp weapon, intended death, and caused it | Evidence shows only postmortem handling and concealment; no direct proof defendant caused death or had intent; conviction rests on speculation | Affirmed. Viewing evidence in the light most favorable to the state, the jury could reasonably infer causation and intent from wounds, blood loss, and strong consciousness-of-guilt evidence (failure to summon aid, concealment, lies). |
| Request to adopt more rigorous sufficiency review (require reasonable view supporting hypothesis of innocence) | State: existing standard controls—review asks whether a reasonable view of the evidence supports the jury’s guilty verdict | Defendant: appellate review should instead ask whether a reasonable view of the evidence supports an innocence hypothesis | Denied. Court refused to change standard, following Supreme Court precedent that appellate review asks whether a reasonable view supports the jury’s verdict of guilty; intermediate appellate court may not overrule Supreme Court. |
Key Cases Cited
- State v. Daniel B., 331 Conn. 1 (2019) (confirms standard of review: ask whether reasonable view supports the jury’s guilty verdict)
- State v. Sivri, 231 Conn. 115 (1994) (consciousness of guilt and circumstantial evidence can support an inference of intent to kill)
- State v. Otto, 305 Conn. 51 (2012) (intent to kill cannot be inferred from mere fact of death; need reasonable supporting inferences)
- State v. Campbell, 328 Conn. 444 (2018) (circumstantial evidence and inferences regarding weapon use and intent)
- State v. Seeley, 326 Conn. 65 (2017) (procedural rule on preserving sufficiency review after denial of judgment of acquittal)