State v. Gault, 304 Conn. 330

Victim sought to indefinitely seal a redacted arrest-warrant affidavit used to arrest the defendant for kidnapping in the first degree for the purpose of a sexual assault.
Trial court sealed the affidavit for 14 days; victim sought indefinite sealing beyond the initial period.
Trial court held redacted affidavit could be released balancing public access with victim’s right to fairness and confidentiality, denying indefinite sealing.
Victim appealed challenging the sealing ruling and asserting standing to appeal under the victim’s rights amendment.
State argued victim lacked standing to pursue an appeal and that this Court lacked subject-matter jurisdiction; intervenor Hartford Courant Company participated.
Court dismissed the appeal for lack of standing, without addressing merits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether victims have standing to appeal under the victim’s rights amendment.	Gault argues victim has standing as party to enforce rights.	State contends victim is not a party and has no right to appeal.	Victim lacks standing; no right to appeal under §52-263.
Whether the victim’s rights amendment provides party status or a right to appeal.	Amendment implicitly creates a remedy, including appeals.	Amendment requires implementing legislation; no party status or appeal right granted.	Amendment not self-executing; no inherent right to appeal; legislature must grant standing.
Whether the Office of the Victim Advocate or statutory framework could confer standing via limited special appearance.	Limited special appearance could advance victims’ rights in court.	Statutory framework creates limited participation, not party status or appeals.	Legislative history shows limited appearance, not full party status or appeal rights; §52-263 not triggered.

State v. Salmon, 250 Conn. 147 (1999) (held bail bondsman cannot appeal as not a party to proceedings)
Board of Education v. Tavares Pediatric Center, 276 Conn. 544 (2006) (standing/appeal issues governed by statute; appellate review rules)
In re Investigation of the Grand Juror into the Bethel Police Dept., 188 Conn. 601 (1982) (appeal rights and standing; limits of judicial review)
Abreu v. Leone, 291 Conn. 332 (2009) (intervening party status in related proceedings; standing considerations)
State v. McCahill, 261 Conn. 492 (2002) (victims' rights amendment requires legislative action for enforcement)
In re Pro Hac Vice Admission of Reich, 83 Conn. App. 432 (2004) (whether nonparty can challenge admission rulings; standing constraints)