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State v. Holmes
148 A.3d 581
| Conn. App. Ct. | 2016
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Background

  • Defendant Daquan Holmes was convicted after a jury trial of murder under § 53a-54a and criminal attempt to commit murder under §§ 53a-49 and 53a-54a.
  • Early May 2011, outside Chacer’s bar in Norwich, a disturbance about guns led to a group including Holmes and his associates.
  • A confrontation escalated; Holmes obtained a gun from William Long and confronted Cadet and Amy, who were walking across the street, resulting in Amy’s fatal gunshot.
  • Police later recovered the Ruger .22 pistol and ammunition; surveillance footage corroborated movements, and Long’s possession of the gun was established.
  • Holmes was arrested in New York in October 2011, extradited to Connecticut, convicted, and sentenced to 54 years’ imprisonment.
  • Holmes appealed, challenging (1) the denial of his motion for a new trial, (2) prosecutorial impropriety during trial, and (3) the appropriateness of using supervisory powers to address alleged deliberate impropriety.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the trial court abused discretion in denying a new-trial motion Holmes contends insufficient evidence, arguing physical impossibility of timelines State failed to discredit alibis; witnesses’ credibility compromised No abuse; verdict supported by reasonable inferences and credibility determinations
Whether prosecutorial impropriety violated due process Prosecutor improperly pressed on inadmissible Long statement and mischaracterized evidence Prosecutor acted in good faith within evidentiary bounds and trial context No reversible prosecutorial impropriety; arguments were proper within context
Whether closing arguments and questioning violated due process or court rulings Prosecutor’s remarks and insinuations exceeded permissible advocacy Arguments were grounded in evidence and fair inference; not prejudicial No supervisory reversal; trial fair under Williams and related standards
Whether the court should exercise supervisory powers over deliberate impropriety Repeated noncompliance with court rulings warranted reversal to deter misconduct No clear explicit court order violated; no deliberate impropriety established Declined to exercise supervisory powers; no basis shown for reversal

Key Cases Cited

  • State v. Vazquez, 119 Conn. App. 249 (2010) (credibility and evaluation of conflicting testimony; role of jury)
  • State v. Williams, 204 Conn. 523 (1987) (procedural standards for prosecutorial impropriety and due process)
  • State v. Maner, 147 Conn. App. 761 (2014) (prosecutorial impropriety in context of trial; due process")
  • State v. Felix R., 319 Conn. 1 (2015) (closing argument standards; fair comment permissible when grounded in evidence)
  • State v. Reynolds, State v. Reynolds, 118 Conn. App. 278 (2009) (use of supervisory powers for deliberate impropriety; deterrence rationale)
  • State v. Garcia, 7 Conn. App. 367 (1986) (objections during trial and impact on due administration of justice)
Read the full case

Case Details

Case Name: State v. Holmes
Court Name: Connecticut Appellate Court
Date Published: Oct 18, 2016
Citation: 148 A.3d 581
Docket Number: AC38395
Court Abbreviation: Conn. App. Ct.