State v. Papandrea, 26 A.3d 75

Papandrea was convicted of nine counts of first degree larceny for taking Homecare funds to purchase artwork.
The state sought to prove he acted with the intent to deprive Homecare or appropriated funds for himself.
The defense argued he acted in good faith, believing Homecare owed money to White Oak, a company in which Papandrea held a majority stake.
Evidence showed Papandrea controlled Homecare’s finances, including sole signatory authority and management of White Oak’s records.
The trial court and Appellate Court concluded the evidence, including circumstantial proof, supported the jury’s finding of intent to steal.
This Court granted certification on whether the state presented sufficient evidence of the defendant’s intent and affirmed the Appellate Court’s judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the evidence sufficient to prove intent to steal?	State argues the cumulative circumstantial evidence showed intent to steal.	Papandrea argues he acted with a good faith right to the funds.	Yes; evidence supported intent beyond reasonable doubt.
Could the jury infer a lack of authority and concealment as indicators of intent to steal?	State contends lack of authority, delay in audits, and concealment supported intent.	Papandrea asserts openness of conduct and lack of concealment defeat intent.	Yes; circumstantial evidence supported intent to steal.
Did the waiver rule permit review of all trial evidence for sufficiency?	State relies on waiver to review all evidence.	Papandrea contends limited post-waiver review.	Sufficiency review encompassed all trial evidence under the waiver rule.
Did the evidence permit reasonable inferences that the debt was not owed to Papandrea personally or as White Oak’s agent?	State argues the debt relationship and corporate structure allowed inference of wrongful taking.	Papandrea claims a right to funds as White Oak’s owner or creditor.	Yes; jury could infer the debt did not belong to him personally and he was not entitled to take funds.

State v. Davis, 283 Conn. 280, 929 A.2d 278 (2007) (sufficiency review uses cumulative evidence and reasonable inferences)
State v. Radzvilowicz, 47 Conn. App. 1, 703 A.2d 767 (1997) (corporate separateness; ownership of corporate property)
State v. Long, 293 Conn. 31, 975 A.2d 660 (2009) (common knowledge and inferences in evaluating intent)
State v. Perkins, 271 Conn. 218, 856 A.2d 917 (2004) (waiver and sufficiency framework)
State v. Rutan, 194 Conn. 438, 479 A.2d 1209 (1984) (waiver rule and appellate review scope)
State v. Papandrea, 120 Conn. App. 224, 991 A.2d 617 (2010) (Appellate standard for sufficiency of intent in larceny case)