State v. Riley, 159 Conn.App. 462

Defendant Winston Riley followed 83‑year‑old Louise Carty into a casino elevator, pulled a knife from his sleeve, and took several steps toward her intending to rob her. No property was taken and he made no verbal demand.
Carty screamed, shoved/grabbed the defendant, and held his sweatshirt as he left the elevator; surveillance video (no sound) corroborated a physical confrontation and showed the defendant turning away only after her resistance.
Defendant testified he immediately curled the knife toward himself, apologized, and abandoned the robbery—raising the statutory renunciation defense.
The state argued renunciation was involuntary because Carty’s scream and physical resistance (not apparent at inception) caused him to desist to avoid detection.
Jury convicted defendant of attempted first‑degree robbery and attempted second‑degree larceny (among other counts); defendant appealed claiming (1) insufficient evidence to disprove renunciation beyond a reasonable doubt and (2) the trial court’s renunciation jury instruction was constitutionally inadequate.

Issue	State's Argument	Riley's Argument	Held
Whether evidence was sufficient to disprove renunciation beyond a reasonable doubt	Carty’s testimony and video showed she screamed/grappled first, causing Riley to abandon attempt to avoid detection; jury could infer renunciation was involuntary	Riley said he changed his mind before she reacted, curled knife to himself and apologized — state failed to disprove renunciation	Affirmed: Viewing evidence in favor of prosecution, jury reasonably found renunciation was not complete/voluntary and was disproved beyond a reasonable doubt
Whether jury instruction omitted necessary language about alternative "prevented commission" element of renunciation	Instruction tracked statute and explained elements; no need to instruct on "other affirmative steps" because Riley acted alone and abandonment was the prevention method	Requested instruction would have told jury state must disprove either (1) prevention or (2) completeness/voluntariness; omission deprived him of full defense	Affirmed: No instructional error. Omitted language unnecessary given law and facts; even proving prevention would not preclude state disproving voluntariness

State v. Lewis, 303 Conn. 760 (constitutional review of evidentiary sufficiency)
State v. Bryan, 307 Conn. 823 (defendant’s burden to produce evidence to raise defense)
State v. Sorabella, 277 Conn. 155 (elements of attempt; intent and substantial step)
State v. Clark, 264 Conn. 723 (affirmative vs ordinary defenses; burden shifting)
State v. Fuller, 199 Conn. 273 (due process requires instruction on statutory defenses when supported by evidence)
State v. Meehan, 260 Conn. 372 (jury resolves witness credibility and inconsistencies)
State v. Kelly, 23 Conn. App. 160 (renunciation unavailable after substantive crime completed; abandonment and prevention analysis)