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