State v. Ramey, 127 Conn. App. 560

Defendant Ryan A. Ramey was convicted after a jury trial of arson in the first degree (two counts) and interfering with an officer.
Fire occurred October 13, 2006, in a multiunit building in Naugatuck; evidence pointed to the defendant starting the fire in his front room.
Police observed a broken window and observed the defendant causing disturbances prior to the fire; he avoided contact with police and remained inside the building during the incident.
Fire marshal could not identify an accidental ignition source but noted a fire can be started without accelerants; the absence of accelerants plus other circumstantial evidence supported an inference of intentional start.
The defense moved for directed verdict and later for judgment of acquittal, but the trial court denied; the jury convicted and sentenced to twelve years with eight to serve and three years probation; this appeal followed.
The court applies the two-part sufficiency review: (1) view the evidence in the light most favorable to sustaining the verdict, and (2) assess whether the cumulative force of the evidence supports guilt beyond a reasonable doubt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that Ramey intentionally started the fire	State contends circumstantial evidence shows intent.	No direct evidence; cannot infer intent from behavior.	Yes; sufficient circumstantial evidence supports intent.
Sufficiency of evidence that defendant had specific intent to damage or destroy the building	Even with suicidal goal, infer intent to damage as a means.	Evidence shows recklessness, not specific intent.	Yes; evidence supports specific intent to damage.
Whether defendant had reason to believe the building was occupied or may have been occupied	Multiunit building; other tenants may have been present.	Only defendant was in the building at start.	Yes; reasonable belief other occupants may have been present.
Standard of review for sufficiency of the evidence	Court uses two-part standard: view in light favorable to verdict; consider cumulative evidence.	(Implicit) standard requires reweighing evidence.	Two-part standard applied; verdict upheld.

State v. Taylor, 126 Conn.App. 52 (2011) (two-step sufficiency analysis; view most favorable to sustaining verdict)
State v. McGee, 124 Conn.App. 261 (2010) (circumstantial evidence allowed to prove intent; no direct evidence required)
State v. Ancona, 256 Conn. 214 (2001) (circumstantial evidence can show intentional fire-start without definitive expert causation)
State v. Famiglietti, 219 Conn. 605 (1991) (opportunity to start fire supports inference of guilt)
State v. Kowalyshyn, 118 Conn.App. 711 (2010) (no seventh juror view; credibility of record evidence matter)
State v. Finley, 34 Conn.App. 823 (1994) (time of starting fire relevant to §53a-111(a)(1) elements)
State v. Fausel, 295 Conn. 785 (2010) ('reason to believe' is objective, not subjective)