State v. Mark T., 186 Conn. App. 285

Defendant Mark T., father of a 13-year-old daughter enrolled in an intensive behavioral support class, attempted to take her from school to a scheduled mental-health appointment; when she resisted he grabbed and dragged her by a leg through school corridors. Police were called and defendant later arrested and tried.
Victim had a history of disruptive and oppositional behavior at school and at home; defendant had custody for ~3 weeks and testified he urgently sought higher-level mental-health help for her.
Defendant was charged with risk of injury to a child (convicted) and breach of the peace (acquitted). He represented himself with standby counsel.
Trial court issued a partial in limine sealing the victim’s identifying details and the name of the treatment facility; court limited some testimony to protect the sealed information.
On appeal defendant argued the court improperly excluded (1) questioning of the special-education teacher about whether the victim had been violent with others at school and (2) testimony identifying the treatment facility and certain home-behavior details, claiming those exclusions violated his right to present a defense and to testify.
Appellate court treated the claims as evidentiary and reviewed for abuse of discretion; it affirmed the conviction, holding the exclusions were within the court’s discretion and did not render the parental-justification defense toothless.

Issue	State's Argument	Defendant's Argument	Held
1. Whether trial court abused discretion by precluding questions on redirect about victim’s violence toward others at school	Questions were beyond scope of prosecutor’s redirect (which focused on teacher’s memory/ability to recall) and thus properly limited under evidentiary rules	Questions were within scope because teacher raised physical altercations on redirect and the victim’s violent history was relevant to reasonableness of force (parental justification)	Court: Exclusion proper — redirect was limited to witness’s recollection; teacher already testified to general disruptive/oppositional history; defendant could have called the teacher as his witness to explore violence further.
2. Whether court unconstitutionally prevented defendant from testifying about home misbehavior and the named treatment facility, impairing parental-justification defense	The court gave the defendant broad latitude; excluded only nonmaterial, sealed identifying details (name of institution) and other sensitive facts protected by in limine order	Exclusion of the facility name and some details made parental-justification defense "toothless" by denying context on urgency and type of treatment sought	Court: No abuse of discretion — defendant testified about severe home misbehavior, repeated efforts to get help, and that he sought more than an after-school program; sealing and excluding identifying details was proper and not material to the defense.

State v. Holley, 327 Conn. 576 (2018) (constitutional rights to present a defense do not suspend the rules of evidence; trial court may limit cross-examination)
State v. Moore, 293 Conn. 781 (2009) (scope and extent of cross-examination and relevance are within trial court's discretion)
State v. Brocuglio, 56 Conn. App. 514 (2000) (parental-justification defense requires subjective and objective reasonableness in use of force)
State v. Maner, 147 Conn. App. 761 (2014) (definition of relevance in evidence law: probative value and materiality)
State v. Warren, 83 Conn. App. 446 (2004) (evidentiary issues cannot be recast as constitutional claims to get heightened review)
State v. Rosario, 99 Conn. App. 92 (2006) (same principle limiting conversion of evidentiary claims into constitutional ones)
State v. Ramos, 182 Conn. App. 604 (2018) (trial court rulings on evidentiary matters entitled to great deference)
State v. Jarrett, 82 Conn. App. 489 (2004) (if no independent state constitutional analysis provided, appellate review limited to federal claim)