State v. Gonsalves, 2012 WL 3000675

Defendant Christopher R. Gonsalves appeals after jury conviction for misconduct with a motor vehicle under § 53a-57(a) and reckless driving under § 14-222(a).
Evidence showed the four occupants visited a restaurant, then did a donut in a school parking lot on an inclement weather day before returning home.
On Route 316, the defendant attempted to pass a slower vehicle by crossing a double yellow line on a narrow road with poor driving conditions.
The vehicle left the road, struck a rock, rolled, and occupants suffered serious injuries; Choquette died the day after the crash.
Defendant faced charges including manslaughter, two counts of assault, and reckless driving; jury acquitted manslaughter and assault, but convicted misconduct with a motor vehicle and reckless driving.
The trial court sentenced the defendant to five years with execution suspended after sixteen months and five years of probation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for misconduct with a motor vehicle	Gonsalves argues no speeding evidence; mental state not shown.	Gonsalves contends insufficient evidence of criminal negligence.	Evidence supports criminal negligence; verdict upheld.
Admissibility of pre-accident donuts in school parking lot	Donuts show awareness of road conditions, tying to recklessness just before the crash.	Donuts constitute prior uncharged misconduct; irrelevant and unduly prejudicial.	Admission did not abuse discretion; evidence relevant and not unduly prejudicial.

State v. Butler, 296 Conn. 62 (2010) (two-step sufficiency review; circumstantial evidence considered)
State v. Carter, 64 Conn. App. 631 (2001) (speed not required for violation; erratic driving can support conviction)
State v. Ortiz, 29 Conn. App. 825 (1993) (criminal negligence standard defined)
State v. Coccomo, 302 Conn. 664 (2011) (abuse-of-discretion standard for evidentiary rulings)
State v. Bell, 303 Conn. 246 (2011) (unfair prejudice balancing in evidentiary rulings)