State v. Freeman, 33 A.3d 256

Eighty-two year old victim Caviness robbed at gunpoint in his parked vehicle near 1016 Stratford Avenue, Bridgeport; victim shot in shoulder.
Beckwith, cousin of Freeman, identified Freeman to detectives; police obtained Freeman's photo and background from database.
Anonymous tip placed Freeman en route to bus station; officers intercepted two men, Freeman identified at scene; $1236 recovered from Freeman.
At detective bureau, Freeman waived rights and confessed to robbing and shooting; Beckwith provided corroborating statements; Beckwith later described Freeman’s actions.
Pretrial motions to suppress evidence and statements argued lack of reasonable suspicion and probable cause; hearing held January 13, 2009.
State moved to reopen suppression hearing after defense highlighted missing link on how Freeman was developed as a suspect; court granted reopening January 15, 2009, allowing Gorman to testify; suppression motions denied the next day.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether reopening suppression testimony was an abuse of discretion	State contends reopening addressed a potential evidentiary gap and aided truth-seeking without prejudice.	Freeman argues reopening rewarded the state’s laxity and prejudiced defense, improper after defense identified deficiencies.	No abuse; reopening proper to aid truth-seeking without undue prejudice.
Whether suppression motions were properly denied	State argues there was probable cause to arrest and reasonable suspicion to stop based on informant information and defendant’s linkage to scene.	Freeman contends lack of evidence for reasonable suspicion and probable cause; suppression warranted.	Court upheld denial; law enforcement had probable cause and reasonable suspicion based on informant information and known sources.

State v. Allen, 205 Conn. 370 (Conn. 1987) (reopening discretion balanced against defendant's fairness; context for pretrial reopening)
State v. Brigandi, 186 Conn. 521 (Conn. 1982) (limits reopening discretion; need to avoid prejudice)
State v. Mendoza, 119 Conn.App. 304 (Conn. App. 2010) (balance fairness and search for truth in review)
State v. Clark, 297 Conn. 1 (Conn. 2010) (two-part test for reasonable, articulable suspicion and stop legality)
Alabama v. White, 496 U.S. 325 (U.S. 1990) (predictive information can create probable cause for stop)
Adams v. Williams, 407 U.S. 143 (U.S. 1972) (intermediate police action permissible for investigation)
State v. Smith, 257 Conn. 216 (Conn. 2001) (informant with firsthand knowledge highly relevant to probable cause)
State v. Johnson, 286 Conn. 427 (Conn. 2008) (informant knowledge as part of totality of circumstances for probable cause)
State v. Morrill, 205 Conn. 560 (Conn. 1987) (informant observations underpin probable cause)
State v. Velasco, 248 Conn. 183 (Conn. 1999) (informant information as basis for knowledge in totality of circumstances)