State v. Greene, 186 Conn. App. 534

Background

Victim William Greene was found fatally stabbed in the living room of a New Britain apartment on March 21, 2015; only the defendant Antoine Greene and the victim were present that morning.
Police observed no forced entry, a blocked front door, a locked/back door guarded by a dog, and blood pooling under the victim; medical personnel observed a ~6-inch neck wound and defensive thumb wound.
A steak knife seized from the kitchen had the victim’s DNA on the blade and a mixed DNA profile on the handle that could include the defendant.
The state initially charged the defendant with murder; after a multiday probable cause hearing the trial court found no probable cause for murder but the state filed an amended information charging first‑degree manslaughter.
The court denied the defendant’s pretrial motion to dismiss (jurisdiction/insufficiency), denied his motions for judgment of acquittal at trial, and a jury convicted him of manslaughter in the first degree. The trial court later denied a motion for a new trial.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court lost jurisdiction to prosecute manslaughter after finding no probable cause for murder	State: court retained jurisdiction and implicitly found probable cause for manslaughter; amendment permitted	Greene: initial lack of probable cause for murder deprived court of jurisdiction to proceed on manslaughter without a new magistrate finding/warrant	Held: court retained jurisdiction; its comments and later ruling made clear it found probable cause for manslaughter and amendment was proper
Whether the probable cause evidence supported manslaughter (intent to cause serious physical injury)	State: circumstantial evidence (alone in apartment, no forced entry, knife with victim/defendant DNA, defensive wounds) supported probable cause	Greene: severity of wounds could only show intent to kill, not lesser intent to cause serious injury	Held: probable cause supported manslaughter; intent to cause serious injury can coexist with intent to kill and facts met probable cause threshold
Whether evidence at trial was sufficient to convict of first‑degree manslaughter beyond a reasonable doubt	State: cumulative circumstantial proof (location, wounds, knife DNA, timeline) allowed inference of intent to cause serious physical injury	Greene: evidence compels inference of intent to kill; insufficient proof of only intent to cause serious injury	Held: evidence sufficient; jury reasonably inferred intent to cause serious physical injury and cause of death was proven
Whether the trial court abused its discretion by denying new trial	State: verdict supported by evidence; no manifest injustice	Greene: verdict inconsistent with the evidence and compelled finding of intent to kill	Held: denial of new trial was not an abuse of discretion given the reasonable basis for the jury’s verdict

Key Cases Cited

State v. Timmons, 7 Conn. App. 457 (Conn. App. 1986) (finding lack of probable cause for murder does not preclude trial court jurisdiction over lesser included manslaughter)
State v. Ayala, 324 Conn. 571 (Conn. 2017) (prosecutor has broad authority to amend an information before trial)
State v. Pelella, 327 Conn. 1 (Conn. 2017) (probable cause review—evidence viewed in light most favorable to the state)
State v. Guess, 44 Conn. App. 790 (Conn. App. 1997) (quantum of evidence for probable cause exceeds mere suspicion but is less than required for conviction)
State v. Williams, 237 Conn. 748 (Conn. 1996) (intent to kill and intent to cause serious physical injury are distinct but may co‑exist)
State v. Rasmussen, 225 Conn. 55 (Conn. 1993) (severe neck wounds can compel inference of intent to kill; analysis of when manslaughter is inconsistent with evidence)
State v. Nival, 42 Conn. App. 307 (Conn. App. 1996) (standards for judgment of acquittal)
State v. James, 54 Conn. App. 26 (Conn. App. 1999) (intent to cause serious physical injury may be inferred from weapon, wounds, and circumstances)