State v. Jones, SC20261

Background

Defendant Billy Ray Jones was convicted of murder; key testimony came from Larry Shannon, who recounted an inculpatory statement by Jones made outside jail and that Jones showed him a gun.
Shannon first contacted police about the homicide roughly 2½ years after the shooting while he was incarcerated; the state later helped lower his bond and he pleaded guilty to two felonies and testified while on probation.
Defense requested a Patterson (special credibility) instruction for a "jailhouse informant"; the trial court gave only a general credibility instruction and the jury convicted.
The majority treated Shannon as falling within an expanded definition of "jailhouse informant," a view Chief Justice Robinson (dissenting) disputes, arguing the Patterson rule should be limited to statements made while both informant and defendant were incarcerated together.
Robinson’s dissent reasons that out‑of‑custody admissions are distinguishable: such testimony is more verifiable, susceptible to cross‑examination, and less likely to suffer the unique fabrication risks tied to in‑custody jailhouse snitches; she also rejects reliance on P.A. 19‑131 to alter the court’s longstanding instruction doctrine.

Issues

Issue	State's Argument	Jones's Argument	Held
Does Patterson’s special credibility instruction apply to witnesses who cooperated while incarcerated but testify about statements made outside jail?	Patterson limited to in‑custody confessions; no special rule needed for out‑of‑custody statements.	Patterson should extend to any witness positioned to receive benefit from the state.	Majority extended the doctrine to include such witnesses; dissent would limit Patterson to in‑custody, co‑incarcerated confessions.
Did Shannon qualify as a "jailhouse informant"?	Shannon was not a traditional jailhouse informant because the confession occurred outside jail and he testified after receiving assistance.	Shannon’s cooperation while incarcerated and receipt of benefits put him within Patterson’s concerns.	Majority considered Shannon within the broadened category; dissent disagreed.
Was the trial court required to give a Patterson instruction (special credibility) rather than a general credibility charge?	General credibility instruction and cross‑examination sufficed; discretion favored the trial court.	Failure to give the Patterson instruction was reversible error.	Majority found the special instruction requirement applicable; dissent concluded no abuse of discretion and that the jury knew Shannon’s motives.
Does P.A. 19‑131 (2019) statutory language alter the common‑law instruction scope?	The legislature’s broader statutory definition supports expanding the jury‑instruction rule and disclosure/hearing requirements.	Statute does not and should not overwrite the judicially crafted instruction rule; judiciary should defer to legislature on policy.	Majority relied in part on the statute for a broader approach; dissent cautioned against reading the statute as changing jury‑instruction law.

Key Cases Cited

State v. Patterson, 276 Conn. 452 (2005) (established requirement of a special credibility instruction for jailhouse informants)
State v. Arroyo, 292 Conn. 558 (2009) (applied Patterson to jailhouse informants who had not yet received benefits)
State v. Diaz, 302 Conn. 93 (2011) (defined "jailhouse informant" narrowly as an inmate who testifies about confessions made while both were incarcerated and declined to expand supervisory rule)
State v. Leniart, 333 Conn. 88 (2019) (discussed risks of jailhouse informant testimony and legislative responses)
Miranda v. Arizona, 384 U.S. 436 (1966) (recognized custodial pressures relevant to in‑custody statements)
United States v. Henry, 447 U.S. 264 (1980) (noted psychological inducements of custody relevant to informant‑elicited statements)