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316 Conn. 651
Conn.
2015
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Background

  • Nash shot at Tyrell Knott’s home after learning Tyrell spread rumors about him; Tyrikah Knott was wounded by a bullet that entered her second‑story bedroom.
  • Defendant Brown accompanied Nash; they drove to the Knott house, discussed shooting, then Nash fired four to five shots from a back yard position.
  • Bullets penetrated bedroom walls; Tyrikah was injured; S also present in a neighboring room; no other occupants were hit.
  • Nash was charged with intentional and reckless first‑degree assault among other counts, and received firearm‑enhancement sentencing after a jury verdict.
  • The trial court merged charges for sentencing; Nash appeals arguing (a) the dual convictions were legally inconsistent and (b) the evidence did not support intentional assault with the required intent to cause serious physical injury.
  • The State and Nash dispute whether two convictions based on the same act can stand when they involve different mental states tied to different results

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Are intentional and reckless first‑degree assault convictions legally inconsistent? Nash claims mutual exclusivity under King. Nash argues same conduct cannot support both states of mind. Not legally inconsistent; different results allow dual mental states.
Was there sufficient evidence Nash intended to cause serious physical injury? State argues circumstantial evidence supports intent. Nash contends evidence shows only reckless intent. Evidence supports intent to cause serious physical injury.

Key Cases Cited

  • State v. King, 216 Conn. 585 (1990) (mutually exclusive mens rea between attempt and reckless assault when same conduct)
  • State v. Hinton, 227 Conn. 301 (1993) (two mental states may relate to different results; not necessarily mutually exclusive)
  • State v. Arroyo, 292 Conn. 558 (2009) (mutually exclusive verdicts standard and review)
  • State v. Williams, 237 Conn. 748 (1996) (plausible theory supports convictions not legally inconsistent)
  • State v. Morascini, 62 Conn. App. 758 (2001) (examples of non‑mutual exclusivity in multiple convictions)
  • State v. Sivri, 231 Conn. 115 (1994) (two mental states assessed against reasonable inferences)
  • Griffin v. Parker, 219 Conn. 363 (1991) (civil context; potential inconsistency of intentional and reckless assault)
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Case Details

Case Name: State v. Nash
Court Name: Supreme Court of Connecticut
Date Published: May 5, 2015
Citations: 316 Conn. 651; 114 A.3d 128; SC19265
Docket Number: SC19265
Court Abbreviation: Conn.
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    State v. Nash, 316 Conn. 651