State v. Seeley
161 A.3d 1278
| Conn. | 2017Background
- Seeley ran daily operations of Miller & Stone, Inc., a small, unprofitable corporation with multiple shareholders including Joshua Bennett.
- Seeley sought to buy a BMW in the corporation's name; dealership required a certified resolution signed by at least two corporate officers and typically required ID when signatures were presented in person.
- A certified resolution was faxed from the Seeley family home to the dealership; the car was titled to the company and Seeley drove it; he later returned the car after shareholders confronted him.
- Bennett reviewed corporate records, denied authoring one of the signatures on the certified resolution, and filed a criminal complaint alleging forgery.
- At trial to the court, the state presented testimony from Bennett, the investigating officer, two handwriting experts, dealership employees, and Seeley’s father; Seeley moved for judgment of acquittal after the state’s case (denied), presented his own evidence, and was convicted of forgery in the second degree.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Seeley) | Held |
|---|---|---|---|
| Whether the court should abandon the waiver rule in bench trials so a denial of a midtrial acquittal motion is reviewable without forfeiting defendant’s right to present evidence | Waiver rule valid; not necessary to change; judge can apply correct standards on final decision | Waiver rule should be abandoned in court trials because an initial denial may taint the trial judge’s later factfinding | Court declined to decide on abandoning waiver rule because state’s case-in-chief was sufficient; left rule for another day |
| Sufficiency of evidence that Seeley forged Bennett’s signature (act element) based on state’s case-in-chief | Handwriting experts and Bennett’s emphatic denial, plus circumstantial evidence, supported finding forgery by Seeley | Handwriting evidence inconclusive; witnesses speculative; dealership employees couldn’t see signature being made | State proved beyond a reasonable doubt that the third signature was not Bennett’s and that circumstantial evidence supported inference Seeley forged it |
| Sufficiency of evidence that Seeley acted with intent to deceive (mental element) | Circumstantial evidence (dealership policy requiring two signatures/ID, Seeley’s knowledge, faxing rather than in-person submission, motive to benefit) supports specific intent to deceive | Record lacks direct proof of specific intent; distinguishes other cases | Court held intent reasonably inferred from circumstantial evidence; intent to deceive the dealership was proven |
Key Cases Cited
- State v. Perkins, 271 Conn. 218 (discussing waiver rule and appellate review after midtrial acquittal denial)
- State v. Calonico, 256 Conn. 135 (standard for reviewing sufficiency of state’s case-in-chief)
- State v. Taylor, 306 Conn. 426 (describing evaluation of circumstantial evidence and reasonable inferences)
- State v. Dickman, 119 Conn. App. 581 (forgery conviction where altered documents were used to circumvent corporate/insurance policy; intent inferred from conduct)
- State v. DeCaro, 252 Conn. 229 (elements of forgery and intent requirements)