State v. Reddick, 166 A.3d 754

Background

Late-night dispute: Reddick and his girlfriend Gainey argued after a party; Gainey called her mother, Marjorie Tillery, who drove with her brother Mickey to retrieve Gainey and her child.
Confrontation in parking lot: Marjorie parked blocking spaces; Mickey approached a station wagon with Reddick as passenger; Reddick exited, produced a 9mm handgun, and shot Mickey in the leg as Mickey was stepping away with his hands raised.
Police stop and statements: Officers stopped the station wagon shortly after; Reddick admitted the gun was his and that he had been at 38 Peck Street. The record is unclear when (or whether) Miranda warnings were given or exactly when formal arrest occurred.
Trial posture and defense: Reddick (a convicted felon) was charged with assault 1st, assault 3rd, and criminal possession of a firearm; his theory was self-defense. He did not testify at trial.
Verdict and sentence: Jury convicted on all counts; Reddick was sentenced to an effective 23 years plus special parole and appealed, asserting prosecutorial misconduct in closing argument.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Reddick)	Held
Prosecutor's comment on defendant not telling officer he shot in self-defense	Comments referred to pre-arrest, admissible silence or record doesn't show Miranda so no Doyle violation	Prosecutor used postarrest silence as circumstantial evidence of guilt in violation of Doyle/Miranda	Affirmed for state: record does not establish Miranda timing or postarrest silence; no Doyle violation shown
Prosecutor expressed opinion on witness (Gainey) credibility	Argued comments were inferences from evidence (inconsistent statements, motive to protect defendant)	Prosecutor impermissibly vouched, usurping jury's credibility determination	Held for state: comments were reasonable inferences about bias/motive, not improper vouching
Prosecutor appealed to emotions by referencing gun-violence trend in New Haven	Such comment was factual/common-knowledge framing and not an attempt to sway jury to remedy social problem	Comment injected extraneous social-issue rhetoric and appealed to juror emotion	Comment about gun violence was improper but isolated; harmless given instructions and overall record
Prosecutor's references to defendant as a convicted felon / character attacks	References were factual and relevant to possession element and inferences about conduct	Repeated remarks suggested defendant's bad character/propensity and amounted to impermissible character assassination	Some references (fact that he was a felon) were proper; additional commentary suggesting he "didn't care about the law" was improper but infrequent and not so prejudicial to require reversal

Key Cases Cited

Doyle v. Ohio, 426 U.S. 610 (prosecution may not use post-Miranda silence against defendant)
Miranda v. Arizona, 384 U.S. 436 (warnings informing right to remain silent underpin Doyle protections)
Fletcher v. Weir, 455 U.S. 603 (Doyle protects silence following governmental assurances; timing of Miranda is operative fact)
Salinas v. Texas, 133 S. Ct. 2174 (privilege against self-incrimination is not self-executing; must be invoked)
State v. Leecan, 198 Conn. 517 (absence of Miranda in record renders Doyle inapplicable)
State v. Plourde, 208 Conn. 455 (arrest alone does not confer Doyle protections without Miranda warnings)
State v. Berube, 256 Conn. 742 (need for factual predicate showing Miranda warnings before silence used)
State v. Montgomery, 254 Conn. 694 (Miranda warnings, even absent formal arrest, bring Doyle protections)
State v. Ciullo, 314 Conn. 28 (prosecutor may argue reasonable inferences about credibility but may not vouch)
State v. Warholic, 278 Conn. 354 (framework for assessing prosecutorial impropriety and prejudice)
State v. Williams, 204 Conn. 523 (factors for measuring whether prosecutorial remarks infected trial fairness)
State v. Medrano, 308 Conn. 604 (prosecutor must avoid character assassination; outlines permissible argument)
State v. Whelan, 200 Conn. 743 (admission limits for recorded witness statements)