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352 Conn. 422
Conn.
2025
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Background

  • Christopher J. Iverson was convicted of murder, attempted murder, first-degree burglary, and first-degree arson after stabbing a woman to death and assaulting her son, then setting multiple fires at the scene.
  • During trial, overwhelming evidence—including eyewitness testimony and forensic evidence—supported that Iverson intentionally killed the victim.
  • Iverson appealed, arguing he should have received a jury instruction on manslaughter (as a lesser included offense of murder) and that admission of an autopsy report by a non-testifying medical examiner violated his confrontation rights.
  • The trial court denied both claims, holding the manslaughter instruction was unwarranted due to lack of evidentiary support, and the autopsy report was properly admitted due to defense counsel's waiver.
  • On appeal, Iverson argued the trial court erred on both issues, invoking recent Supreme Court precedent regarding confrontation rights.

Issues

Issue Iverson's Argument State's Argument Held
Jury instruction on lesser-included manslaughter Sufficient evidence supported a manslaughter charge; jury should decide. Overwhelming evidence of intent; no evidence of recklessness. No instruction warranted; insufficient evidence for manslaughter.
Admission of autopsy report by non-testifying ME Violated confrontation rights; relied on recent case law. Defense counsel strategically waived objection—so claim is waived. Claim waived; strategic waiver by counsel bars relief.

Key Cases Cited

  • State v. Whistnant, 427 A.2d 414 (Conn. 1980) (sets the four-prong test for when a lesser included offense instruction is appropriate)
  • State v. Golding, 567 A.2d 823 (Conn. 1989) (establishes the standard for review of unpreserved constitutional claims)
  • Bullcoming v. New Mexico, 131 S. Ct. 2705 (U.S. 2011) (surrogate testimony regarding forensic reports cannot satisfy the Confrontation Clause)
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Case Details

Case Name: State v. Iverson
Court Name: Supreme Court of Connecticut
Date Published: Jul 15, 2025
Citations: 352 Conn. 422; 336 A.3d 1212; SC20844
Docket Number: SC20844
Court Abbreviation: Conn.
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