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State v. Mungroo
11 A.3d 132
| Conn. | 2011
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Background

  • In March 2002, Nazra Mungroo worked as general cashier and income auditor at a Hartford Hilton and helped handle a robbery incident.
  • The hotel was robbed of over $100,000; Mungroo reported the robbery and was taken to Hartford Hospital claiming diabetic-related symptoms.
  • She was absent briefly, then returned to work, taking sick leave from May 2002 and later receiving workers' compensation benefits exceeding $5,000.
  • Investigators later found that Mungroo participated in staging the robbery, leading to convictions for first-degree larceny and falsely reporting an incident.
  • Mungroo was charged with fraudulent receipt of workers' compensation benefits for omitting material facts about the true circumstances of the injury.
  • A jury convicted her of fraudulent receipt of workers' compensation benefits; she was sentenced to one year in prison to be served consecutively.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether waiver of instructional-error claim was proper Mungroo argues waiv er bad under Golding post-Kitchens. Mungroo says Ebron governs unpreserved claims and requires review unless induced. Waiver proper; Golding-based review foreclosed
Whether defense counsel could waive the claim on defendant's behalf Counsel’s participation cannot bind defendant to waive a constitutional right. Counsel acted within authority when reviewing and accepting proposed charges. Counsel’s waiver valid; defendant’s right waived under Kitchens

Key Cases Cited

  • State v. Kitchens, 299 Conn. 447 (2011) (redefines waiver when counsel reviews drafts and accepts instructions)
  • State v. Ebron, 292 Conn. 656 (2009) (unpreserved claims reviewed unless defense induced error)
  • State v. Golding, 213 Conn. 233 (1989) (constitutional claims may be reviewed if four-part test satisfied)
  • State v. Holness, 289 Conn. 535 (2008) (counsel may waive constitutional claims in exercising professional judgment)
  • State v. Tomas D., 296 Conn. 476 (2010) (Golding framework and review principles discussed)
Read the full case

Case Details

Case Name: State v. Mungroo
Court Name: Supreme Court of Connecticut
Date Published: Jan 5, 2011
Citation: 11 A.3d 132
Docket Number: SC 18336
Court Abbreviation: Conn.