State v. Lamont Fields, 24 A.3d 1243

Fields was convicted by a jury of two counts of kidnapping in the second degree, one count of assault in the first degree, and one count of risk of injury to a child; total sentence 53 years.
Facts show Cortes ended an abusive relationship with Fields, moved to Mary Razek’s home, and Fields later abducted Cortes, compelled her to drive to a gas station, and assaulted Taoufik Razek when he returned home.
Cortes testified the defendant restrained her at gunpoint, dragged her from the house to Cortes’ Cadillac, and discussed harming Taoufik; Darryl allegedly assisted.
Taoufik was assaulted, left in a bathroom, and later moved to the Cadillac where Cortes heard the plan to confront Taoufik; Taoufik escaped during the driving incident.
The State charged Fields with kidnapping Taoufik and Cortes and charged him with multiple offenses; the jury acquitted some charges and convicted on others.
On appeal, Fields challenged the Salamon incidental-restraint instruction, asserted errors in risk-of-injury instructions, and claimed vagueness as applied to § 53-21(a)(1); the Supreme Court partially remanded and affirmed in part.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Salamon instruction required for kidnapping with underlying offense	State argues Salamon must apply despite underlying offense not demanding restraint	Fields contends Salamon should not apply when restraint isn’t element of underlying crime	Salamon instruction required; not harmless error; remand for new trial on Taoufik kidnapping count
Instruction on risk of injury to a child adequate	State maintained instructions properly conveyed elements and burden	Fields contends phrasing diluted proof or allowed nonwilful conduct	No reversible error; instructions adequate when viewed overall
Vagueness challenge as applied to § 53-21(a)(1) rejected	State argues statute provides fair warning; conduct unlawful under any reasonable interpretation	Fields asserts lack of notice and enforcement arbitrariness	Vaguenessclaims rejected; conviction sustained except as to Taoufik kidnapping (reversed)

State v. Salamon, 287 Conn. 509 (2008) (rejected incidental restraints rule; requires Salamon instru. when restraint may have independent criminal significance)
State v. Velasco, 253 Conn. 210 (2000) (harmless error standard for jury instructions)
State v. Padua, 273 Conn. 138 (2005) (standard on risk-of-injury to child interpretation)
State v. Scruggs, 279 Conn. 698 (2006) (two-part framework for § 53-21(a)(1) creation of dangerous situations)
State v. Winot, 294 Conn. 753 (2010) (reaffirms 53-21(a)(1) standard; vagueness interpretations)
State v. Branham, 56 Conn.App. 395 (2000) (notice that leaving children unattended violates § 53-21(a)(1))