State v. Urbanowski, 172 A.3d 201

Defendant Michael A. Urbanowski was tried for a 2012 incident and convicted of second‑degree assault, second‑degree breach of the peace, second‑degree strangulation, and second‑degree threatening; he later pleaded nolo contendere to a persistent serious felony offender allegation.
Allegation at trial included that Urbanowski choked the victim; he received an effective sentence of 14 years incarceration plus six years special parole.
At trial the court admitted testimony from a woman who alleged Urbanowski had choked her about ten years earlier as uncharged misconduct probative of intent.
The Appellate Court held the trial court abused its discretion in admitting that prior‑misconduct evidence but concluded the error was harmless and affirmed the conviction.
The Connecticut Supreme Court granted certification limited to whether the Appellate Court properly deemed the error harmless, and affirmed, adopting the Appellate Court’s reasoning on harmlessness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Appellate Court correctly held that admission of the uncharged‑misconduct testimony was harmless error	State: any error was harmless given the overall record and evidence supporting guilt	Urbanowski: admission of prior choking testimony was improper and prejudicial	Court: any such evidentiary error was harmless; affirmed Appellate Court opinion and judgment

Recall Total Information Management, Inc. v. Federal Ins. Co., 317 Conn. 46, 115 A.3d 458 (2015) (adopted Appellate Court opinion as authoritative on a certified question)
State v. Brunetti, 279 Conn. 39, 901 A.2d 1 (2006) (discussing appellate review when affirming on harmless‑error grounds)
State v. Urbanowski, 163 Conn. App. 377, 136 A.3d 236 (2016) (Appellate Court opinion finding abuse of discretion but harmless error)