State v. Patterson, 156 A.3d 66

Paterson burglary and attempted larceny case; May 2, 2013 incident at Segura’s residence; eyewitnesses Segura and Duarte identified Patterson in double-blind, sequential photo lineups; Segura also identified via private actor identification from a news article; motion to suppress identifications denied; trial included expert cross-examination and prosecutor arguments later challenged on appeal; verdict: guilty on burglary second degree and attempted larceny fifth degree; sentence: 10.5 years total; issues on suppression, cross-examination, and prosecutorial impropriety.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether identifications were unnecessarily suggestive	Patterson; identification procedures were unnecessarily suggestive	State; procedures not unnecessarily suggestive	No unnecessary suggestiveness; identifications reliable under totality of circumstances
Whether cross-examination of Sommers violated evidentiary rules	Defense claims improper cross-examination and improper hypothetical	State properly cross-examined expert	Claim not preserved; no plain error; no due process violation found
Whether prosecutorial improprieties violated due process	Prosecutor argued facts not in evidence and mischaracterized testimony	Prosecutorial zeal within limits; no reversible error	Proprieties occurred but did not deprive defendant of a fair trial

State v. Elliston, 86 Conn. App. 479 (2004) (standard for reviewing suppression and reliability of identifications)
State v. Outing, 298 Conn. 34 (2010) (factors for unnecessary suggestiveness and police conduct)
State v. Grant, 154 Conn. App. 293 (2014) (not unnecessarily suggestive; discusses two-pronged test)
State v. Holliman, 214 Conn. 38 (1990) (private actor identifications and due process)
State v. Johnson, 312 Conn. 687 (2014) (private conduct identifications and constitutional underpinnings)
State v. Medrano, 308 Conn. 604 (2013) (prosecutorial conduct and closing arguments; standard)