State v. Godbolt, 161 Conn.App. 367

Defendant Karon Godbolt convicted after a July 2013 jury trial of multiple offenses including first‑degree burglary, harassment, carrying a dangerous weapon, disorderly conduct, and possession of drug paraphernalia.
Alleged crime occurred May 19–21, 2012; victim Jessica Siddell testified defendant tapped her with the blunt side of a knife on May 20, 2012.
Defendant testified he had an alibi: he was with Shelly Romano at her mother’s house in Winsted; Romano lived in Owensboro, Kentucky.
Defendant filed a notice of alibi on July 8, 2013; trial commenced July 17, 2013. Romano did not appear; defense counsel said Romano lacked bus fare and had not yet boarded travel.
On July 18 the court declined to grant an indefinite continuance to wait for Romano, noting the late timing, vague explanation, defendant’s failure to subpoena her, and uncertain length of delay. Romano never testified; defendant was convicted and sentenced.
On appeal defendant argued the denial of a continuance violated his Sixth Amendment and state constitutional right to present a complete defense; the trial court’s ruling was reviewed for abuse of discretion and affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Godbolt)	Held
Whether the trial court abused its discretion by denying a continuance to permit out‑of‑state alibi witness to appear	Court reasonably denied continuance given untimely request, indefinite delay, defendant’s failure to subpoena witness, and prior warning to have witnesses ready	Denial prevented presentation of complete defense (alibi witness); a short continuance (two days) would not have prejudiced the state	No abuse of discretion; denial was reasonable given timing, vagueness about travel/funding, and defendant’s role in delay
Whether denial violated Sixth Amendment right to present a defense	Waiver/untimeliness arguments; procedural failures meant no constitutional violation	Denial infringed right to compulsory process and to present a full defense	Court reviewed for abuse of discretion; constitutional claim not shown because defendant failed to show witness would be available or that reasonable steps were taken; no reversible constitutional violation

State v. Davis, 135 Conn. App. 385 (review of continuance denial standard)
State v. Stevenson, 53 Conn. App. 551 (trial court may deny last‑minute continuance; courts must keep docket moving)
State v. Cecil J., 99 Conn. App. 274 (timeliness and use of judicial process to secure witnesses are relevant)
State v. Brunetti, 279 Conn. 39 (denial affirmed where counsel waited until trial nearly over to locate witness)
State v. Gordon, 197 Conn. 413 (defendant bears burden to justify continuance to await absent witness)
State v. Bethea, 167 Conn. 80 (constitutional claim tied to continuance denial evaluated under abuse of discretion where no showing of prejudice)