State v. Linder, 159 A.3d 697

Victim and defendant lived together temporarily after meeting at a horse rescue; on June 27–28, 2014 they argued and later were in the same bedroom overnight.
Early morning, the victim reentered the bedroom, shook the defendant awake and teased him; the defendant sleepily told her to stop.
The defendant then punched the victim in the right eye, rendering her briefly unconscious; he subsequently placed both hands around her neck and squeezed for ~20 seconds.
Police were called, the defendant was treated as the primary aggressor, and the victim was transported to the hospital with facial/neck contusions and a hoarse voice.
Defendant was tried by jury and convicted of third-degree assault and second-degree strangulation; acquitted of first-degree unlawful restraint. Defendant appealed, arguing insufficiency of evidence and that self-defense was not disproved beyond a reasonable doubt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for assault in the third degree (intent to cause injury)	State: testimony and injuries support finding defendant was awake, acted intentionally, and caused injury.	Linder: he was not fully awake; punch was a spontaneous/accidental reaction when pushed.	Affirmed — reasonable inferences from victim testimony and injury support finding defendant was awake and intended to cause injury.
Sufficiency of evidence for strangulation in the second degree (impeded breathing)	State: defendant wrapped hands around victim’s neck ~20 sec; medical findings (front neck bruising, hoarseness, tenderness) are consistent with strangulation.	Linder: lack of classic internal findings (no petechiae, no vocal cord swelling) undermines proof he impeded breathing.	Affirmed — medical and testimonial evidence permitted jury to find breathing was impeded and offense established.
Whether state disproved defendant’s claim of self-defense beyond reasonable doubt	State: jury could credit victim’s version that defendant told her to stop, then punched after provocation; force was excessive and not reasonably necessary.	Linder: acted in self-defense from a startled or unknown attacker; used necessary force from a prone position.	Affirmed — jury reasonably disbelieved self-defense and found state met burden to disprove it beyond a reasonable doubt.

Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warning principle referenced regarding defendant being read rights)
State v. Fabricatore, 89 Conn. App. 729 (2005) (elements of third-degree assault: intentional causing of physical injury)
State v. Sam, 98 Conn. App. 13 (2006) (standard of review for sufficiency of evidence; jury credibility determinations)
State v. Singleton, 292 Conn. 734 (2009) (allocation of burden when defendant claims self-defense; state must disprove defense beyond a reasonable doubt)
State v. Davis, 159 Conn. App. 618 (2015) (same sufficiency standard applied where justification defense is asserted)