State v. Miranda
174 A.3d 770
| Conn. | 2018Background
- In October 1987, 13-year-old Mayra C. disappeared in Hartford, later found dead in East Windsor from blunt force trauma.
- Diaz and his brother saw a yellow Datsun; they described the driver as Hispanic with light complexion, mustache, and curly hair.
- Diaz testified that his identification of the driver came from guidance from God, not his memory; the court ruled this portion inadmissible.
- Miranda had previously worked at a nursery where a yellow Datsun and Miranda’s involvement were suggested; later police interviews in 1987 yielded inconsistent alibi evidence.
- Twenty-one years later, in December 2008, Miranda was arrested and charged with murder; trial proceeded to jury verdict of guilty; sentence imposed was sixty years consecutive to an existing life term.
- At trial, the defense challenged Diaz’s divine-guidance identification as improper and challenged the victim’s mother’s testimony about hearsay relating Miranda to the disappearance, with preservation and remedy questions arising.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Waiver of objection to Diaz’s divine-guidance testimony | State | Miranda argues improper to admit; not waived | Waived by defendant's approval of remedy |
| Preservation of hearsay claim regarding mother's testimony | State | Miranda objected only on relevancy, not hearsay | Unpreserved; not reviewable |
Key Cases Cited
- State v. Kemah, 289 Conn. 427 (2008) (waiver of rights and trial conduct impact on appeal)
- State v. Fabricatore, 281 Conn. 469 (2007) (waiver/claims arising from issue at trial)
- State v. Foster, 293 Conn. 327 (2009) (consent/waiver through trial conduct)
- Hackenson v. Waterbury, 124 Conn. 679 (1938) (when objection sustained, testimony may be deemed unusable)
- State v. Lewis, 303 Conn. 760 (2012) (post-objection treatment of testimony in presence of jury)
- State v. Jorge P., 308 Conn. 740 (2013) (preservation standards for evidentiary claims)
- State v. Kitchens, 299 Conn. 447 (2011) (implicit waiver when proposed jury instructions reviewed and accepted)
- State v. Bellamy, 323 Conn. 400 (2016) (identification instruction waiver)