State v. Lane, 206 Conn. App. 1

Defendant Ahmaad Lane struck victim Keven Tischofer in the head with a chair during a 2014 confrontation; victim suffered skull fractures and an epidural hematoma and required emergency neurosurgery.
Lane fled to Vermont, was arrested and extradited to Connecticut; charged with first‑degree assault (part A) and as a persistent dangerous felony offender (part B) based on a 2005 Waterbury conviction.
On the first day of trial Lane orally moved to disqualify Judge Keegan, asserting she had been a supervisory prosecutor in Waterbury and may have participated in pretrial work on his prior case, creating an appearance of partiality; Judge Keegan referred the motion to Judge D’Addabbo, who denied it.
Lane moved to exclude three post‑surgical photographs of the victim as irrelevant and unduly prejudicial; the trial court admitted two of the three after a pretrial hearing.
Lane was convicted by a jury of first‑degree assault, pleaded guilty to the part B information for sentence enhancement, and appealed both the denial of recusal and the admission of the photographs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Judicial disqualification	State: No reasonable basis to question Judge Keegan’s impartiality; any supervisory role was limited and remote in time.	Lane: Judge Keegan served as a supervisory prosecutor in Waterbury when pretrial matters in his prior case occurred, creating an appearance of bias.	Denied — no abuse of discretion; limited (if any) prior role, 12 years elapsed, knowledge of the prior conviction was public; Milner standard applied.
Admissibility of photographs	State: Photos show severity of injuries and neurosurgery, relevant to serious physical injury and intent; images are post‑operative/clean, not unduly gory.	Lane: Photos are irrelevant to the charged offense and unduly prejudicial/gory (many stitches), likely to inflame the jury.	Admitted 2 of 3 — court did not abuse discretion; photos were relevant to seriousness of injury and intent and probative value outweighed prejudicial effect.

State v. Milner, 325 Conn. 1 (2017) (recusal required when a reasonable person would question judge’s impartiality under all circumstances)
State v. Bunker, 89 Conn. App. 605 (2005) (limited supervisory prosecutorial role and passage of time do not automatically require recusal)
State v. Kelly, 256 Conn. 23 (2001) (admissibility of photographs governed by relevancy, not necessity)
State v. Osbourne, 162 Conn. App. 364 (2016) (trial court has wide discretion on evidentiary rulings; reversal only for abuse of discretion)
State v. Crespo, 190 Conn. App. 639 (2019) (appellate review of disqualification denials is for abuse of discretion)
Abington Ltd. P’ship v. Heublein, 246 Conn. 815 (1998) (allegations of judicial impropriety must be evaluated on individual facts)