State v. Jackson, 304 Conn. 383

Defendant John Jackson was convicted of murder under General Statutes § 53a-54a after a jury trial.
Victim Desti Parnell and the defendant had a son; victim allowed defendant to move into her apartment in 672 Legion Avenue, New Haven.
On July 21–22, 2004, the defendant attempted suicide in New York; later, victims’ body was found in her apartment with multiple stab wounds and ligature marks.
New Haven police sought evidence; New York officers seized the defendant’s hotel-room clothing and rooftop socks, later tested for victim DNA.
Defendant moved to suppress items, suppress DNA results untimely under § 54-86k, and suppress statements; he also sought a third-party culpability instruction, which the court denied.
The Supreme Court of Connecticut affirmed the judgment, addressing Fourth Amendment, state constitution, and evidentiary issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence from the hotel room and rooftop was admissible	State: abandonment or emergency exception justified seizure.	Jackson: items were seized unlawfully without warrant.	Items properly seized; abandoned or emergency justified admission.
Whether the socks' seizure violated Fourth Amendment/privacy	State: abandonment doctrine applies; socks were abandoned.	Moore: abandonment does not apply when removed for medical treatment.	Socks abandoned; seizure valid; testing with warrant covered; no violation.
Whether DNA evidence disclosed untimely under § 54-86k and whether continuance was appropriate	State: late disclosure warranted continuance; not bad faith.	Jackson: untimely; need preclusion and independent testing time.	Trial court did not abuse discretion; continuance adequate; no preclusion required.
Whether statements to police at St. Vincent's Hospital were admissible	State: statements voluntary and not custodial; waiver proper.	Johnson's interview was custodial and involuntary due to injuries and meds.	Defendant not in custody; statements voluntary.
Whether the trial court properly denied third party culpability instruction	State: evidence insufficient to connect third party to crime.	Jackson: evidence supports third party culpability; instruction warranted.	No abuse of discretion; insufficient direct link to third party; instruction denied.

State v. Boyd, 295 Conn. 707 (2010) (standard of review for suppression and factual findings)
State v. Joyce, 229 Conn. 10 (1997) (abandoned property and safekeeping; forensic testing under Joyce framework)
State v. Mooney, 218 Conn. 85 (1991) (privacy in retained ownership yet relinquished privacy in object)
State v. Fausel, 295 Conn. 785 (2010) (emergency doctrine applied to permit hotel-room entry)
United States v. O'Bryant, 775 F.2d 1528 (11th Cir. 1985) (community caretaking function and safekeeping seizures)
Mincey v. Arizona, 437 U.S. 385 (1978) (coercive interrogation; standards for custodial interrogation)
People v. Vasquez, 393 Ill.App.3d 185 (2009) (hospital interviews and custody indicators)
United States v. Turner, 28 F.3d 981 (9th Cir. 1994) (post-seizure admissibility across agencies)