State v. Megos, 170 A.3d 120

Defendant Zane R. Megos pled guilty (Alford) to six counts of fourth‑degree larceny, received a six‑year sentence suspended with three years probation beginning April 29, 2014.
While on probation, Megos advertised a condemned Norwich apartment, obtained a $2,925 cash deposit from Nicole Foster by promising imminent inspections and occupancy, and gave her receipts pre‑signed by his business partner, Bishop Taylor.
Foster later learned the apartment had no scheduled inspections and that the person who took her money was Megos; she and her father confronted him and he returned the deposit only after being asked.
Megos was arrested for third‑degree larceny and criminal impersonation based on the Foster incident; the state brought a probation violation charge and proved violations by a preponderance at a four‑day revocation hearing.
The trial court found Megos impersonated Taylor and committed larceny (and attempted larceny), revoked probation, and imposed the remaining 60 months of the original sentence as incarceration.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Megos)	Held
Whether Megos committed criminal impersonation	Evidence showed Megos answered "Bishop," used Taylor‑signed receipts, and acted in assumed character to defraud Foster	He was identifying the owner on the receipt, not impersonating Taylor; testimony conflicted	Court: Not clearly erroneous to find impersonation; credited prosecution evidence
Whether Megos committed larceny in the third degree	He obtained $2,925 by false promise to rent a condemned unit and intended to keep the deposit (similar prior schemes)	He lacked intent to permanently deprive; returned deposit when confronted	Court: Not clearly erroneous to find larceny by false promise on preponderance of evidence
Whether willfulness is required for probation violation	State: Not required; need only show knowledge of condition and conduct violating it	Megos claimed prosecution had to show wilful/intentional violation	Court: Willfulness not an element; violation proven because he knew the condition and engaged in criminal conduct
Admissibility of prior larceny convictions	Prior incidents were relevant to common scheme/intent and admissible in a revocation hearing	Prior convictions were irrelevant/prejudicial under evidentiary rules	Court: Evidence admissible; rules of evidence relaxed in probation hearings and prior acts were sufficiently similar

State v. Maurice M., 303 Conn. 18 (Ct. App. 2011) (describes evidentiary and dispositional phases of probation revocation)
State v. Sherrod, 157 Conn. App. 376 (probation revocation proof standard: preponderance)
State v. Rollins, 51 Conn. App. 478 (probation violation need only be proven by preponderance)
State v. Hill, 256 Conn. 412 (willfulness is not an element of probation violation)
State v. Lanagan, 119 Conn. App. 53 (probation hearings are informal; hearsay admissible if reliable)
State v. Young, 81 Conn. App. 710 (broad evidentiary standard in revocation hearings; prior uncharged/ acquitted conduct may be considered)
State v. Allen, 289 Conn. 550 (credibility determinations are for the trier of fact)
State v. Francis, 146 Conn. App. 448 (disposition on revocation is reviewed for abuse of discretion)
North Carolina v. Alford, 400 U.S. 25 (recognizes Alford plea doctrine)