State v. Martinez, 158 A.3d 373

Background

On Nov. 2, 2010, Arnaldo Gonzalez was beaten and killed after being pursued and assaulted; co‑defendant Mark struck the victim with a hard object and Martinez admitted stomping/kicking the victim; Mark fled with the victim’s backpack.
After the killing Martinez and others went to Martinez’s home, where blood was observed on Martinez’s sneaker; Martinez said he had “kicked a crackhead,” and later cleaned his sneaker and hid the backpack.
Martinez claimed the blood came from an earlier, unrelated altercation (a few hours before the killing) in which he and others fought a third party (allegedly a “crackhead”) and Martinez kicked that third party; defense sought to present evidence that the prior victim was a drug user to explain the “crackhead” comment.
At trial Martinez was convicted of felony murder, first‑degree robbery (multiple counts), conspiracy and tampering; the murder conviction was later vacated at sentencing (no longer contested on appeal); Martinez appealed several rulings.
Issues on appeal: (1) exclusion of evidence about the prior altercation (and use of the term “crackhead”); (2) limits on cross‑examination/impeachment of Detective Tirado; (3) alleged instructional error on accessorial liability (dismissed as moot); (4) jury playback of testimony (whether court improperly handled/read‑back); (5) denial of suppression of Martinez’s written statement to police.

Issues

Issue	State's Argument	Martinez's Argument	Held
Court excluded details that third‑party in earlier altercation was a “crackhead”	Details were collateral, confusing, and irrelevant to source of blood; court allowed inquiry into existence, timing, and whether blood could have come from prior fight	Evidence was relevant to show Martinez’s “crackhead” remark referred to the earlier fight (not the homicide victim); exclusion violated right to present a defense	Court erred in excluding that limited additional evidence but the error was harmless beyond a reasonable doubt; conviction affirmed on other counts
Limits on cross‑examining/impeaching Detective Tirado about two nonconviction misconduct allegations	Court should bar inquiry because allegations were unadjudicated, disputed, and the defense could not supply proof without disclosing privileged documents; impeachment by felony conviction allowed and used	Defense argued allegations were probative of Tirado’s veracity and relied on a sentencing memorandum and counsel’s good‑faith belief	Court did not abuse discretion; exclusion of those nonconviction matters proper; defendant’s confrontation claim fails
Jury instruction on accessorial liability for murder	State maintained instruction was correct	Martinez challenged instruction (but murder conviction vacated at sentencing)	Claim dismissed as moot — no practical relief because murder conviction was vacated
Court’s handling of jury request to replay testimony (read‑back)	Court complied with Practice Book rules, sought clarity, replayed portions requested, and jurors indicated they had enough	Martinez argued jury heard only direct (not cross) for some witnesses and court delayed/failed to provide full requested playback, prejudicing deliberations	No abuse of discretion; court appropriately responded, jurors later said no additional playback was needed
Denial of motion to suppress Martinez’s written statement	Statement was voluntary; Martinez came to station voluntarily, was advised of Miranda, read and waived rights, and signed statement; officers’ account credible	Martinez claimed custodial coercion, threats, inability to understand warnings, and involuntary waiver/confession	Trial court’s factual findings were not clearly erroneous; totality shows noncustodial encounter or, alternatively, a knowing voluntary waiver — suppression properly denied

Key Cases Cited

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (custodial interrogation and Miranda warnings required)
State v. Tilus, 157 Conn. App. 453 (Conn. App. 2015) (defendant’s right to present a defense is not absolute and is subject to evidentiary rules)
State v. Wright, 320 Conn. 781 (Conn. 2016) (harmless‑beyond‑a‑reasonable‑doubt standard for constitutional evidentiary errors)
State v. Rivera, 223 Conn. 41 (Conn. 1992) (trial court discretion on jury read‑backs; replay only what jury requests)
State v. Arias, 322 Conn. 170 (Conn. 2016) (factors for assessing custodial status for Miranda purposes)