State v. Mark T., 339 Conn. 225

Father (Mark T.) had custody of his 13-year-old daughter A for ~3 weeks; he scheduled a mental‑health appointment because of severe behavioral problems.
At school, after A resisted leaving, Mark forcibly attempted to carry her; he dragged her by the ankle through the hallway; police intervened and he released her.
Charged with breach of the peace (2d) and risk of injury to a child; tried pro se with standby counsel; court sealed identifying information about the minor.
Mark asserted a parental justification defense under Conn. Gen. Stat. § 53a-18 (use of reasonable force by a parent); he sought to elicit testimony about A’s violent history and urgency of treatment.
Trial court limited (1) cross-examination of school witness Wilkos and (2) Mark’s direct testimony about A’s home behavior and the need for urgent treatment; jury convicted Mark of risk of injury to a child (sentence suspended). Appellate Court affirmed.
Connecticut Supreme Court reversed the Appellate Court, holding the trial court properly limited cross-exam but abused its discretion by excluding the defendant’s direct testimony about facts central to his justification defense, and that error was harmful; remanded for new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court abused discretion by limiting cross-examination of Wilkos about whether A had been physical with others at school	State: Question was outside scope of prosecutor’s prior redirect (which rehabilitated Wilkos’ credibility); exclusion proper	Mark: Question rebutted prosecutor’s insinuation and was within scope because it responded to implications about reasonableness	Held: No abuse — court reasonably limited scope to rehabilitation of credibility; exclusion permissible under scope-of-cross rules
Whether trial court improperly limited Mark’s direct testimony about A’s aggressive behavior, his difficulties managing her, and urgency of treatment (parental justification defense)	State: Court allowed sufficient testimony; rulings were relevance‑based and aimed to protect sealed privacy info; any omitted detail was cumulative	Mark: Exclusion prevented him from presenting crucial, noncumulative evidence necessary to show subjective and objective reasonableness under § 53a-18	Held: Abuse of discretion — excluded testimony was highly probative and material to the core parental justification defense; error was not harmless; new trial required

State v. Nathan J., 294 Conn. 243 (Conn. 2009) (parental justification may apply to risk of injury charge; requires subjective and objective reasonableness)
State v. Bennett, 324 Conn. 744 (Conn. 2017) (defendant has constitutional right to present a defense but is bound by evidentiary rules)
State v. Calabrese, 279 Conn. 393 (Conn. 2006) (trial court has wide discretion on admissibility; abuse-of-discretion standard)
State v. Fernando V., 331 Conn. 201 (Conn. 2019) (harmless‑error standard for nonconstitutional evidentiary rulings; verdict must not be substantially swayed)
State v. Mark T., 186 Conn. App. 285 (Conn. App. 2018) (Appellate Court opinion affirming trial court prior to Supreme Court review)